It is important to note that the Supreme Court has not struck down every state flag-desecration statute as unconstitutional. The Texas law featured in Texas v. Johnson violated the First Amendment because it sought to suppress expressive activity. Other state statutes may prohibit flag-burning as part of general safety and welfare laws — such as those criminalizing trespass, arson and rioting — that place at most an incidental and permissible burden on free speech.