constraints on the free flow of information and ideas. According to Meiklejohn, democracy will not be true to its essential ideal if those in power are able to manipulate the electorate by withholding information and stifling criticism. Meiklejohn acknowledges that the desire to manipulate opinion can stem from the motive of seeking to benefit society. However, he argues, choosing manipulation negates, in its means, the democratic ideal. Eric Barendt has called the defense of free speech on the grounds of democracy "probably the most attractive and certainly the most fashionable free speech theory in modern Western democracies". In Nixon v. Shrink Missouri Government PAC, 528 US 377 (2000), at 401, Justice Stephen Breyer, joined by Justice Ruth Bader Ginsburg, wrote a concurring opinion in support of regulation. In response to protestations that such laws violate citizen's rights to free speech, Breyer held that there were free speech arguments on both sides of the issue. He said that properly framed regulations limiting monetary contributions could substantially expand the opportunity for freedom of expression rather than limit it. He pointed out that the integrity of the electoral process needs to be maintained since that is the means by which a free society translates political advocacy into concrete political action, and that regulating the financing of political campaigns is integral to that advocacy. In doing so, Breyer cited Meiklejohn's interpretation of the First Amendment which gives emphasis to public need rather than individual prerogative. Awards The American Association of University Professors (AAUP) established the Alexander Meiklejohn Freedom Award to honor his work. He received the Rosenberger Medal in 1959. Meiklejohn was selected by John F. Kennedy to receive the Presidential Medal of Freedom, which was presented by Lyndon B. Johnson shortly after Kennedy's death. Legacy Meiklejohn Civil Liberties Institute (MCLI) in Berkeley Meiklejohn Advising Program: The Meiklejohn Advising Program is Brown University's advising program for incoming first-year students. Meiklejohn Advisors (known as Meiklejohns for short) are student advisors who are paired with each first-year, along with a faculty advisor, to provide academic advice and help the transition to college. Meiklejohn House: The University of Wisconsin–Madison's Meiklejohn House (home to the Integrated Liberal Studies program) continues to espouse the ideals of Meiklejohn's experimental college by engaging students in interdisciplinary liberal education. Meiklejohn Hall: Meiklejohn Hall at the California State University, East Bay houses many of the school's liberal arts programs. The Evergreen State College