related to expression in the context of activity". Spence ruled that a man who displayed an American flag with a peace symbol taped to it was engaging in protected expression; in 1989, the court similarly upheld the right to burn the American flag as expressive conduct in Texas v. Johnson. The court revisited the necessary fit between the important governmental interest and the means to actualize that interest in Clark v. C.C.N.V., 468 U.S. 288 (1984), in which it held that the nexus need merely be reasonable. The court also merged its doctrine of time-place-manner restrictions and the O'Brien test into an intermediate scrutiny hybrid. See also List of United States Supreme Court cases, volume 391 Conscription in the United States Opposition to the Vietnam War Symbolic speech Notes References Further reading External links First Amendment Library entry on United States v. O'Brien; includes list of newspaper and law review articles about the case. 1968 in United States case law United States Free Speech Clause case law United States Supreme Court cases United States Supreme Court cases of the Warren Court Conscription in the United States Draft-card burning