The following excerpt is from Hartline v. Nat'l Univ., No. 2:14-CV-0635 KJM AC PS (E.D. Cal. 2015):
The First Amendment to the U.S. Constitution "prohibits governmental infringement on the right of free speech." Rendell-Baker v. Kohn, 457 U.S. 830, 838 (1982) (emphasis added). Plaintiff does not allege any governmental interference with his free speech rights and therefore this provision does not appear to have any application here.
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F. Fraud
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