from some reading i've been doing

"While we agree that artwork, like other nonverbal forms of expression, may under some circumstances constitute speech for First Amendment purposes, we believe that the First Amendment has only limited application in a case like the present one where the artistic expression belongs to the government rather than a private individual . . . In this case, the speaker is the United States Government. Serra relinquished his own speech rights in the sculpture when he voluntarily sold it to GSA." -judge Jon O. Newman

This was concerning Richard Serra's Tilted Arc, which was installed at the Federal Plaza, New York 1981 and destroyed March 15, 1989. P.s. the GSA is the United States General Services Administration.