In Hudgens v. National Labor Relations Board, the Supreme Court ruled that
there was no right to exercise free speech in privately owned malls under
the First Amendment.
Private Property
In Manhattan Community Access Corporation v. Halleck (2019), a sharply
divided U.S. Supreme Court ruled that a private corporation that oversees
public access channels in Manhattan is not a state, or governmental actor,
subject to First Amendment constraints. The Court determined that
“operation of public access channels on a cable system is not a traditional
exclusive public forum.”