At the opposite end of the spectrum, the least open
public space is the non-public forum, which includes ‘public
property which is not by tradition or designation a forum for
public communication’ (460 US 37, p. 46). Who may use these
public spaces and how they may use them can be restricted to
specific groups and activities. Between these two extremes, the
US Supreme Court also defined a third type – the limited public
forum; this includes public property that, unlike parks and
streets, is not traditionally open but ‘which the State has opened
for the use of the public as a place for expressive activity’ (460
US 37, p. 45). The Canadian courts, citing the ‘reasonable limits’
clause of the Canadian Charter of Rights and Freedoms, rejected
this categorising approach in favour of case-by-case evaluations
(Moon, 1988)