Perry Education Association v. Perry Local Educators' Association, 460 U.S. 37 (1983), was a United States Supreme Court decision concerning free speech rights on government-owned property. The Court ruled that teacher mailboxes and the use of a school mail delivery system are a nonpublic forum, and upheld a policy that allowed the union representing the teachers, but not other employee organizations, to use the district's mail system. Perry Education Association is commonly cited for its explanation of the rules distinguishing the public forum, the designated public forum, and the nonpublic forum. Background Two rival unions were in competition to represent the teachers of Perry Township Schools in Indiana: the Perry Education Association (PEA) and the Perry Local Educators' Association (PLEA). In 1977, PEA won an election and was certified as the exclusive bargaining representative for the district's teachers. Following the election, PEA negotiated a labor contract with the district. Among other things, this contract gave PEA the right to place material in teachers' mailboxes and to use the interschool mail delivery system. Mail access rights were given exclusively to PEA, and could not be used by any other "school employee organization." PLEA, the rival organization, could not use teacher mailboxes or the school mail system. However, PLEA was not prevented from posting notices on bulletin boards, holding meetings on school property, or making announcements on the public address system. In addition, under Indiana law, PLEA was assured of equal access to all modes of communication during election periods. PLEA filed a civil suit against PEA under §1983, claiming that the mail access policy violated PLEA's First Amendment rights. The Seventh Circuit sided with PLEA, ruling that there was no basis for denying PLEA mail access. Opinion of the Court In a 5–4 decision, the Supreme Court reversed the Seventh Circuit and upheld the mail access policy. Writing for the majority, Justice Byron White analyzed the three types of forums that arise when speakers use government-owned property to convey a message: A public forum is a public place, such as a street or park, that "time out of mind, [has] been used" for expressive purposes. In the traditional public forum, speech restrictions must be content-neutral, be narrowly tailored to serve a significant government interest, and leave open ample alternative channels of communication. A designated public forum is "public property which the State has opened for use by the public as a