[P]olitical speech must prevail against laws that would suppress it, whether by design or inadvertence. Laws that burden political speech are “subject to strict scrutiny,” which requires the Government to prove that the restriction “furthers a compelling interest and is narrowly tailored to achieve that interest.” [cite omitted] While it might be maintained that political speech simply cannot be banned or restricted as a categorical matter, see Simon & Schuster, 502 U. S., at 124 (KENNEDY, J., concurring in judgment), the quoted language from WRTL provides a sufficient framework for protecting the relevant First Amendment interests in this case. [. . .] Premised on mistrust of governmental power, the First Amendment stands against attempts to disfavor certain subjects or viewpoints. [. . .] As instruments to censor, these categories are interrelated: Speech restrictions based on the identity of the speaker are all too often simply a means to control content.

Does the Taft-Hartley Act's prohibition on political solidarity strikes withstand this level of review? If Citizens United's logic is applied consistently, the answer appears to be clearly No. The prohibition against political solidarity strikes is a"[s]peech restriction[] based on the identity of the speaker." What makes it different from an expenditure restriction?

Ironically (and more than a bit nonsensically), political strikes against the government might survive this scrutiny. The Citizens United Court stated that:

The Court has upheld a narrow class of speech restric-tions that operate to the disadvantage of certain persons, but these rulings were based on an interest in allowing governmental entities to perform their functions. See, e.g., Bethel School Dist. No. 403 v. Fraser, 478 U. S. 675, 683 (