I think it's in reference to pre-internet 1A 'protection' even when using publicly available private property. >See Marsh v. Alabama for this -- a company town

I think it's in reference to pre-internet 1A 'protection' even when using publicly available private property. >See Marsh v. Alabama for this -- a company town was prohibited from barring picketing and pamphleting on private sidewalks. [user?id=rabite] >https://www.oyez.org/cases/1940-1955/326us501 https://www.oyez.org/cases/1940-1955/326us501