in United States v. Eichman (1990). A Flag Desecration Amendment to the U.S. Constitution has been proposed repeatedly in Congress since 1989, and in 2006 failed to pass the Senate by a single vote. Falsifying military awards While the unauthorized wear or sale of the Medal of Honor has been a punishable offense under federal law since the early twentieth century,Pub.L. 103-322, The Violent Crime Control and Law Enforcement Act of 1994, § 320109 (p. 318 of the PDF version). Retrieved on June 30, 2012. the Stolen Valor Act criminalized the act of not only wearing, but also verbally claiming entitlement to military awards a person did not in fact earn. In United States v. Alvarez (2012), the Supreme Court struck down the Act, ruling that the First Amendment bars the government from punishing people for making false claims regarding military service or honors where the false claim was not "made to effect a fraud or secure moneys or other valuable considerations". The Supreme Court could not agree on a single rationale for its decision. Compelled speech The Supreme Court has determined that the First Amendment also protects citizens from being compelled by the government to say or to pay for certain speech. In West Virginia State Board of Education v. Barnette (1943), the Court ruled that school children could not be punished for refusing either to say the pledge of allegiance or salute the American flag. The Court also overruled Minersville School District v. Gobitis (1940), which had upheld such punishments of school children. In National Institute of Family and Life Advocates v. Becerra (2018), the Court ruled that a California law requiring crisis pregnancy centers to post notices informing patients they can obtain free or low-cost abortions and include the number of the state agency that can connect the women with abortion providers violated those centers' right to free speech. In Janus v. AFSCME (2018), the Court ruled that requiring a public sector employee to pay dues to a union to which he is not a member violated the First Amendment. According to the Court, "the First Amendment does not permit the government to compel a person to pay for another party's speech just because the government thinks that the speech furthers the interests of the person who does not want to pay." The Court also overruled Abood v. Detroit Board of Education (1977), which had upheld legally