When considered in conjunction with North Carolina’s acknowledgment that the purpose of the speech-and-display provision is to persuade women to change their minds about abortions, the language of the statute, and the situations it creates, strongly support the argument that the compelled state message is ideological. Identifying the message as ideological is a critical step in challenging the provision’s constitutionality because courts engaging in a First Amendment analysis give much less weight to a state’s interest in conveying an ideological viewpoint, as opposed to a state’s interest in protecting the health of its citizens. As the Fourth Circuit
