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 First Amendment right of free speech, including commercial speech, had been violated. The Court applied a four-part test to determine whether the regulation of commercial speech was constitutional, and found that the prohibition on advertising by the utilities failed to meet all four prongs of the test. Therefore, the regulation was unconstitutional and violated the First Amendment right to free speech.