In PAPISH v. BOARD OF CURATORS OF THE UNIVERSITY OF MISSOURI ET AL. (1973), a case about the limits of free speech on campus, Justice Warren Burger dissented. His dissent advocates self-restraint as a core American value:
In theory, at least, a university is not merely an arena for the discussion of ideas by students and faculty; it is also an institution where individuals learn to express themselves in acceptable, civil terms. We provide that environment to the end that students may learn the self-restraint necessary to the functioning of a civilized society and understand the need for those external restraints to which we must all submit if group existence is to be tolerable.