LEBRON v. NATIONAL RAILROAD PASSENGER CORPORATION

Legal Principle at Issue

Whether the National Railroad Passenger Corporation, commonly known as Amtrak, is a federal government entity subject to the constraints of the First Amendment, despite a statutory disclaimer in its congressional charter declaring it is not an agency or establishment of the United States Government.
 

Action

Reversed and remanded. Petitioning party received a favorable disposition.

Facts/Syllabus

Petitioner Michael A. Lebron, who creates billboard displays that comment on public issues, filed suit claiming the National Railroad Passenger Corporation (Amtrak) had violated his First Amendment rights by rejecting a display for an Amtrak billboard because of its political nature. 

The district court ruled that Amtrak, because of its close ties to the federal government, was a government actor for First Amendment purposes, and that its rejection of the display was unconstitutional. The U.S. Court of Appeals for the Second Circuit reversed, noting that Amtrak was, by the terms of the legislation that created it, not a government entity, and concluding that the government was not so involved with Amtrak that the latter's decisions could be considered federal action.