In the 1997 case Glendora v. John Porzio, et al., the United States Supreme Court addressed a dispute between public access television host Glendora and White Plains Public Access Television Corporation (WPPATC). The conflict arose when WPPATC imposed restrictions on Glendora's show due to viewer complaints about its content. These limitations included reducing her airtime and requiring that she provide transcripts of each episode for review before airing. Claiming these actions violated her First Amendment rights, Glendora sued WPPATC and several individuals associated with it in federal court. However, both the district court and Second Circuit Court of Appeals ruled against her, finding that WPPATC was not a state actor subject to constitutional constraints because it did not operate under government control or perform a function traditionally reserved for the state. When appealed to the Supreme Court, they declined to hear the case without comment which effectively upheld lower courts' rulings.

The dissenting opinion in the case of Glendora v. John Porzio, et al., argued that the majority's decision to uphold restrictions on public access television was a violation of First Amendment rights. The dissenters believed that these channels should be considered public forums and therefore subject to strict scrutiny when it comes to content-based regulations. They contended that by allowing cable operators or local governments to control content, they were effectively censoring speech based on its message - an infringement upon free speech rights. Furthermore, they disagreed with the majority's assertion that these channels were not traditionally used for purposes of free expression; rather, they saw them as modern equivalents of town squares where citizens could express their views freely and openly without fear of censorship.