Article:
Mark G. Yudof, When Governments Speak: Toward a Theory of Governments, Expression, and the First Amendment, 57 Texas L. Rev. 863 (1979).
 

Abstract:
In “When Governments Speak,” Professor Yudof examines the dual nature of government speech. According to Yodof, this dual nature encompasses the power of government officials to communicate and the dangers inherent in the government communication. Yudof suggests the proper role for legitimate concerns about excessive government expression within the context of first amendment scholarly analysis. Specifically he suggests that an ultra vires approach to government expression is particularly appropriate