Today the Speech and Press Clauses protect much more than just spoken or written words. They also cover expressive conduct, sometimes referred to as nonverbal “expression,” which can include images and other modes of communicating ideas. For example, several cases have involved what can and cannot be done with the American flag. The 1974 Spence v. Washington case established that hanging a flag upside down and with a peace sign affixed to it was a form of “protected expression.” Similarly, Texas v. Johnson (1989) held that laws forbidding the burning of the American flag were “inconsistent with the 1st Amendment.” In response, Congress passed the Flag Protection Act of 1989. This Act made it illegal for anyone to mutilate, deface, defile, burn, or trample upon an American flag. Perhaps it should come as no surprise that many flags were subsequently burned in protest of this Act. The following year, the Supreme Court struck down the federal Flag Protection Act in United States v. Eichman (1990).