Case: 21-51178 Document: 00516474571 Page: 23 Date Filed: 09/16/2022 No. 21-51178 viewpoints: Because “no specific message is dictated by the State to be displayed on appellants’ property,” there was “no danger of governmental discrimination for or against a particular message.” Ibid. The mall relied in part on Miami Herald, but the PruneYard Court easily found that case inapplicable. The Court stated that Miami Herald “rests on the principle that the State cannot tell a newspaper what it must print,” and it emphasized the “danger in [Miami Herald] that the statute would dampen the vigor and limit the variety of public debate by deterring editors from publishing controversial political statements that might trigger the application of the statute.” Id. at 88. Those concerns were “obviously . . . not present” in PruneYard. Ibid. The third case is PG&E. A utility company, PG&E, had a longstanding practice of including a monthly newsletter in its billing envelopes. 475 U.S. at 5 (plurality op.). “In appearance no different from a small newspaper,” the newsletter included political editorials and stories on matters of public interest alongside tips on energy conservation and information about utility services. Id. at 5, 8. Concerned that the expense of PG&E’s political speech was falling on customers, the California Public Utilities Commission (“Commission”) decided to apportion the billing envelopes’ “extra space”—that is, the space occupied by the company’s newsletter—and permit a third-party group representing PG&E ratepayers to use that space for its opposing messages four months per year. Id. at 5–6. PG&E objected, arguing that the First Amendment prevented the Commission from forcing it to include an adverse party’s speech in its billing envelopes. The Supreme Court ruled for PG&E. A plurality held that the Commission’s order both interfered with PG&E’s own speech and impermissibly forced it to associate with the views of other speakers. As in Miami Herald, the “one-sidedness” of the Commission’s order penalized 23