“Citizen-Critic” Model: This approach emphasizes the value of freedom of expression to self-government in a democratic society.  In the American polity, political sovereignty resides with the people.  If they are to perform their self-governing function, then they must be free both to criticize their government and to receive information concerning its workings.  As Brandeis wrote in Whitney, “Political discussion is a political duty.”  Brennan wrote in New York Times v. Sullivan that the right of people to criticize government without fear of reprisal is “the central meaning of the First Amendment.”