Student Government Ass’n v.  Board of Trustees, supra, 868 F.2d at 482.  Thus if federal law imposed a fine on municipalities that passed resolutions condemning abortion, one might suppose that a genuine First Amendment issue would be presented.  Against this suggestion can be cited the many cases which hold that municipalities lack standing to invoke the Fourteenth Amendment against actions by the state.  E.g., Coleman v.  Miller, 307 U.S. 433, 441 (1939); Williams v.  Mayor & City Council of Baltimore, 289 U.S. 36, 40 (1933); City of East St. Louis v.  Circuit Court for the Twentieth Judicial Circuit, 986 F.2d 1142, 1144 (7th Cir. 1993).  But it is one thing to hold that a municipality cannot interpose the Fourteenth Amendment between itself and the state of which it is the creature, Anderson v.  City of Boston, 380 N.E.2d 628, 637-38 (Mass. 1978), appeal dismissed for want of a substantial federal question, 439 U.S. 1060 (1979), and another to hold that a municipality has no rights against the federal government or another state.  Township of River Vale v.  Town of Orangetown, 403 F.2d 684, 686 (2d Cir. 1968), distinguishes between these two types of cases.

Creek v.  Village of Westhaven, 80 F.3d 186, 192-93 (7th Cir. 1996).  We also note that there is no textual support in the First Amendment for distinguishing between, for example, municipal corporations, and private corporations, which the Court has recognized have cognizable First Amendment rights.  First Nat’l Bank of Boston v.  Bellotti, 435 U.S. 765, 775-76 (1978).  Unlike other provisions in the Bill of Rights, which the Supreme Court has held to be “purely personal” and thus capable of being invoked only by individuals, the First Amendment is not phrased in terms of who holds the right, but rather what is protected.  Compare U.S.  Const. amend V ("No person shall be held to answer . . .”) (emphasis added) with U.S.  Const. amend I ("Congress shall make no law . . . abridging the freedom of speech, or of the press . . . ."); see also United States v.  White, 322 U.S. 694, 698-701 (1944) (holding that the privilege against self-incrimination applies only to natural persons).  The Supreme Court relied on this distinction (i.e., that the First Amendment protects a class of speech rather than a class of speakers) in a similar context in Bellotti.  There, the Court invalidated a Massachusetts statute that prohibited corporations from spending money to influence ballot initiatives that did not bear directly on their “property, business or assets.”  Id. at 768.  In so holding, the Court rejected the argument that the First Amendment protects only an individual’s expression.  The Court wrote: 

The Constitution often protects interests broader than those of the party seeking their vindication. . . .  The proper question therefore is not whether corporations “have” First Amendment rights and, if so, whether they are coextensive with those of natural persons.  Instead, the question must be whether [the government is] abridg[ing] expression that the First Amendment was meant to protect.