of free expression? (4) Is the restriction narrowly tailored – no greater than necessary? Later, a fifth factor was added in Ladue v. Gilleo, 512 U.S. 43 (1994): (5) whether the restriction leaves open ample opportunities of communication. When deciding if a restriction is narrowly tailored, courts consider the setting of the communication. Setting has two divisions: public forum and non- public forum. In a public forum people have a right to express themselves however, not in a non-public forum. Adderley v. Florida, 385 U.S. 39 (1966) held that freedom of speech may be limited in a jailhouse because a jailhouse is not a public forum therefore speech is subject to restriction. The court in Adderley v. Florida used the rational basis test standard of review even though the law was content neutral because a jailhouse is a non-public forum. Ward v. Rock Against Racism, 491 U.S. 781 (1989) held that a city's restriction on loud music volume controlled by equipment and technicians is constitutional because it is narrowly tailored. Madsen v. Women's Health Center, 512 U.S. 753 (1994) upheld part of an injunction restricting abortion protesters from entering the "buffer zone" around the abortion clinic because this was the least restrictive means and still gave protestors ample opportunity to communicate outside the buffer zone on the sidewalk, which was a public forum. The court used the strict scrutiny standard of review in Madsen. Intermediate scrutiny applies to regulation that does not directly target speech but has a substantial impact on a particular message. It applies to time, place, and manner restrictions on speech, for example, with the additional requirement of "adequate alternative channels of communication." In other words, if restricting the time, place, or manner of speech means that speech cannot take place at all, the regulation fails intermediate scrutiny. It has been used in "erogenous zoning" cases such as Renton v. Playtime Theatres, Inc., 475 U.S. 41 (1986), that limit the concentration or require concentration of certain types of establishments. It has also been used for other types of content-neutral regulation, as well as for content-neutral speech compulsion. Intermediate scrutiny also applies to regulation of commercial speech, as long as the state interests in regulating relate to fair bargaining. Regulations for other reasons, such as protection of children, are subject to strict scrutiny. Gun control Various federal and state laws restricting access to guns by certain people, laws