The U.S. Supreme Court case Wooley, Chief of Police of Lebanon, et al. v. Maynard et ux., 1976 revolved around the issue of free speech and whether a state could compel individuals to display a message they disagreed with on their personal property - in this instance, license plates on cars. The plaintiffs were George Maynard and his wife Maxine who objected to New Hampshire's state motto "Live Free or Die" displayed on their car’s license plate due to religious reasons as Jehovah's Witnesses; they believed the statement was morally repugnant and covered it up leading them being fined multiple times for violating state law which prohibited altering visible markings on license plates. The Supreme Court ruled in favor of the Maynards stating that forcing an individual to use their private property as 'a mobile billboard' for promoting ideological messages infringes upon their First Amendment rights because it constitutes compelled speech.

In the case of Wooley v. Maynard, Justice Rehnquist dissented from the majority opinion. He argued that requiring New Hampshire residents to display a state motto on their license plates did not infrally upon their First Amendment rights because it was not an attempt by the government to spread a particular ideological message but rather a means of identification for law enforcement purposes. Furthermore, he contended that if individuals were allowed to alter or obscure this information, it could potentially lead to difficulties in identifying vehicles and maintaining public safety. In his view, any incidental advancement of ideology through such mottos was secondary and permissible under constitutional scrutiny.