In Central Hudson Gas & Electric Corp. v. Public Service Comm., the New York utility commission ruled that electric utilities could not advertise to promote the use of electricity. The Supreme Court held that the:

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The Supreme Court held that the State's interest in energy conservation was indeed substantial, but a complete suppression of speech was more extensive than necessary to further the goal of energy conservation. Instead, the Court suggested that the State could satisfy its interest in energy conservation by allowing advertisements that promoted conservation efforts and more efficient energy use.