Forte authored an Amicus brief in support of motion for reconsideration, in the case of Murray v. Chagrin Valley Publishing Co., Case no. 2015-0127, Supreme Court of Ohio, on issues dealing with free speech and libel. The brief was filed on July 20, 2015. In the brief, Forte writes, 'I have chosen to participate as an amicus curiae in support of the Motion for Reconsideration filed by Appellants Robert E. Murray, Murray Energy Corporation, American Energy Corporation, and The Ohio Valley Coal Company because as a career constitutional scholar, I believe that Appellants’ case presents questions of keen interest to the bench and bar that merit this Court's attention. The interest that Appellants’ appeal garnered from multiple amici curiae and from the press is no accident -— the case indeed presents a notable package of First Amendment issues worthy of this Court's review."