“You Couldn’t Pay Me to Say That”:  303 Creative and Compelled Commercial Speech

303 Creative prevents a First Amendment violation where it would be most keenly felt—the government commanding an individual to use her creative talent to create and promote a message antithetical to her conscience or beliefs. The relative rarity of prior cases involving attempts to compel creative commercial speech may have reflected a tacit consensus that this was a First Amendment redline, not lightly to be crossed.