The First Amendment Right to Free Speech or Free Expression

The First Amendment right to free speech or free expression is a revered and fundamental right in the American political system. Which of the following is not one of the often-cited justifications for protecting free speech?

A) Most other societies allow free speech, so to disallow it in the United States would create undue tensions among citizens.
B) Free speech creates a "marketplace of ideas."
C) Self-governance is dependent upon free speech.
D) Free speech can lead to self-fulfillment.
E) Free speech is a "safety valve" that balances the need for order with reform.