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Legal Principle at Issue

Does the Stolen Valor Act of 2005 violate the First Amendment by criminalizing false claims about receiving military honors, even if those lies are not made for material gain or do not cause harm?

Action

The Supreme Court struck down the Stolen Valor Act in a 6-3 decision, ruling it violated the First Amendment. In the majority opinion written by Justice Anthony Kennedy, the Court held that while Alvarez's statements were false, the First Amendment protects even knowingly false speech, unless it causes legally recognized harm (such as fraud or defamation). As written, the Stolen Valor Act was overly broad and could suppress harmless or trivial lies, thereby chilling free expression. In their dissent, Justices Alito, Scalia, and Thomas argued that false statements of this nature have no social value and that protecting the integrity of military honors justifies the law.

Facts/Syllabus

Xavier Alvarez was a member of a California water district board who, during a public meeting in 2007, falsely claimed he had received the Medal of Honor, the highest U.S. military award. This lie violated the Stolen Valor Act of 2005, a federal law that made it a crime to falsely claim receipt of military decorations or medals. The government prosecuted Alvarez under the Stolen Valor Act. Alvarez was convicted in the U.S. District Court for the Central District of California, but he challenged the decision, arguing that the law violated his First Amendment right to free speech. The lower court's decision was reversed by the U.S. Court of Appeals for the Ninth Circuit, which held the law invalid. The government appealed the Ninth Circuit's decision, which was subsequently granted by the Supreme Court in 2011.

Importance of Case

The Supreme Court's decision in United States v. Alvarez reinforced the principle that the government cannot criminalize lies simply because they are offensive or disrespectful, thereby reaffirming strong constitutional protections for speech, even when that speech is knowingly false. The decision placed limits on how far the government can go in regulating speech, warning against laws that could be used to suppress unpopular or nonconforming ideas. In response, to the Court's decision, Congress passed a revised Stolen Valor Act in 2013, which criminalized false claims about military honors only when made to obtain money, property, or other tangible benefits.