Lebron v. National Railroad Passenger Corp.

Lebron v. National Railroad Passenger Corporation, 513 U.S. 374 (1995), is a United States Supreme Court case in which the Court held that Amtrak is a government agency and is thus subject to the First Amendment. The Court issued its decision in a 8–1 vote, with seven justices joining the majority opinion authored by Antonin Scalia. The lone dissent came from Justice Sandra Day O'Connor.

Background
Michael A. Lebron rented a large billboard in Amtrak's Penn Station. The advertisement was highly critical of the Coors Brewing Company for their support of the Contras in Nicaragua. The railroad turned down the ad because it was political, although the particular point of view was not an issue.

The District Court ruled that Amtrak, because of its close ties to the Federal Government, was a Government actor for First Amendment purposes, and that its rejection of the display was unconstitutional. The Court of Appeals reversed, noting that Amtrak was, by the terms of the legislation that created it, not a Government entity, and concluding that the Government was not so involved with Amtrak that the latter's decisions could be considered federal action.

Decision
Even though Amtrak is not incorporated as a government agency, it largely functions as one. Similar to the ruling in Burton v. Wilmington Parking Authority, the court found that the public and private entities functioned together to the point where Amtrak was covered by the First Amendment.

Later, in Department of Transportation v. Association of American Railroads, the court held that Amtrak is a governmental entity for purposes of determining the validity of the metrics and standards.