In Consolidated Edison Co. v. Public Service Comm., the Supreme Court held that state utility regulators could prohibit all expenditures by a business spent for political purposes only because the business is "highly regulated."

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In Consolidated Edison Co. v. Public Service Comm., the Supreme Court held that the state's prohibition on utility companies' ability to include inserts discussing controversial issues of public policy in their billing envelopes violated the First Amendment. The Court did not rule that regulators could prohibit expenditures for political purposes solely because the business is "highly regulated."