Case: 21-51178 Document: 00516474571 Page: 21 Date Filed: 09/16/2022 No. 21-51178 regulations, facilities, or services”). Nor could a State create a right to distribute leaflets at local shopping malls. But see PruneYard Shopping Ctr. v. Robins, 447 U.S. 74, 88 (1980) (upholding a California law protecting the right to pamphleteer in privately owned shopping centers). So First Amendment doctrine permits regulating the conduct of an entity that hosts speech, but it generally forbids forcing the host itself to speak or interfering with the host’s own message. Five Supreme Court cases elucidate this distinction. The first is Miami Herald. It involved a Florida law providing that when a newspaper article criticizes the character or record of a political candidate, the newspaper must offer the candidate equal space in the paper to reply to the criticism. 418 U.S. at 244. The Court held that this “right-of-reply” law violated the First Amendment. Id. at 258. The Court explained that the law interfered with the newspaper’s speech by imposing a content-based penalty on it. See id. at 256 (“The Florida statute exacts a penalty on the basis of the content of a newspaper.”). If the newspaper chose to speak about most topics, there was no penalty— but if it spoke critically about a political candidate, it was penalized with the “cost in printing and composing time and materials” necessary to give the candidate a free and equally prominent response column. Ibid. Moreover, the reply would “tak[e] up space that could be devoted to other material the newspaper may have preferred to print.” Ibid. This interference would disincentivize the newspaper’s speech: Faced with these penalties, “editors might well conclude that the safe course is to avoid controversy” and reduce coverage of political candidates altogether. Id. at 257. The Court also concluded that the right-of-reply law impermissibly compelled the newspaper to speak messages it opposed. As the Court explained: 21