The 1982 Supreme Court decision in "Pico v. Island Trees Union Free School District" occasioned an ideological war over interpretation of the First Amendment, but a review indicates that it is an additional case in the long-standing attempt to find the proper balance between the amendment and the efficiencies of government. In "Pico," the issue was whether the amendment imposed limitations upon a school board's discretion to remove books from a school library. One ideological position promotes the First Amendment and an open society; a second position favors government dividing itself into special purposes and being vested with discretion to find the efficiencies to achieve its ends. The First Amendment positionists recognize the amendment's description as the indispensible condition of other freedoms. The cases upholding the First Amendment seem to emphasize two themes: (1) the function of freedom of speech in individual expression and development, and (2) the value of freedom of expression in a representative democracy. Those in favor of government performing specialized functions prefer absolute discretion because the realities dictate discriminating choices so that government's primary mission is not disrupted. The limited open forum cases allow courts to invade these special purpose government entities so that the First Amendment can survive, given the fluctuations of government. (CJH)