door to door solicitation laws in south carolina

If you do not know a lawyer, you can call the South Carolina Bar Lawyer Referral Service weekdays between 9 a.m. and 5 p.m. . . Citing Saia and Kovacs as examples of reasonable time, place, and manner regulation, the Court observed: If overamplied loudspeakers assault the citizenry, government may turn them down. Id. Heres What You Need to Know! (AP Photo/Charles E. Knoblock, used with permission from the Associated Press), is a professor of political science and dean of the Honors College at Middle Tennessee State University. It shall be unlawful for any peddler to enter upon any private premises when such premises are posted with a sign stating "No Peddlers Allowed," or "No Solicitations Allowed" or other words to such effect. . In Eichman Justice Stevens wrote the only dissenting opinion, to which the other dissenters subscribed. Although public broadcasting as a general matter does not lend itself to scrutiny under the forum doctrine [i.e., public broadcasters ordinarily are entitled to the editorial discretion to engage in viewpoint discrimination], candidate debates present the narrow exception to this rule. Id. You already receive all suggested Justia Opinion Summary Newsletters. The Court indicated that its precedents supported measures that would require some form of notice to officials and the obtaining of identification in order that persons could canvas house-to-house for charitable or political purposes. at 160, and called for a balancing, with the weight inclined to the First Amendment rights. at 80102. 1515 NLRB v. Fruit & Vegetable Packers, 377 U.S. 58, 63 (1964) (requiringand finding absent in NLRAclearest indication that Congress intended to prohibit all consumer picketing at secondary establishments). 354 U.S. at 295 (Justice Douglas, joined by Chief Justice Warren and Justice Black). . Early Termination Clause. There is nothing unlawful in standing outside a store and recording names. The Justice would not, however protect demonstrations conducted on private property over the objection of the owner . June 26, 1990). The prohibition in Vincent was distinguished as not removing a uniquely valuable or important mode of communication, and as not impairing citizens ability to communicate.1576, Sound Trucks, Noise.Physical disruption may occur by other means than the presence of large numbers of demonstrators. In Lehman v. City of Shaker Heights, 418 U.S. 298 (1974), a divided Court permitted the city to sell commercial advertising space on the walls of its rapid transit cars but to refuse to sell political advertising space. In Niemotko v. Maryland, 340 U.S. 268, 273 (1951) (concurring opinion), Justice Frankfurter wrote: It is not a constitutional principle that, in acting to preserve order, the police must proceed against the crowd whatever its size and temper and not against the speaker.. Immediately following Johnson, Congress enacted a new ag protection statute providing punishment for anyone who knowingly mutilates, defaces, physically defiles, burns, maintains on the oor or ground, or tramples upon any ag of the United States.1611 The law was designed to be content-neutral and to protect the physical integrity of the ag.1612 Nonetheless, in overturning convictions of ag burners, the Court found that the law suffered from the same fundamental aw as the Texas law in Johnson. Anonymous pamphlets, leaets, brochures and even books have played an important role in the progress of mankind. In Breard v. Alexandria (1951), the Supreme Court upheld the constitutionality of a Green River ordinance prohibiting door-to-door commercial solicitations other than those invited by residents. v. City of St. Paul, 505 U.S. 377 (1992) (striking down ordinance that prohibited symbols, such as burning crosses, that constituted fighting words that insult on the basis of some factors, such as race, but not on the basis of other factors). (AP Photo/Gary Tramontina, used with permission from the Associated Press), The Supreme Court has often affirmed the reasonableness of time, place, and manner restrictions in the door-to-door context. Private Property at 206 (A public library does not acquire Internet terminals in order to create a public forum for Web publishers to express themselves, any more than it collects books in order to provide a public forum for the authors of books to speak.). 1597 West Virginia State Bd. An 'Early Lease Termination' clause is often the 'safest' way to avoid any problems when breaking a lease early in South Carolina. RICHLAND COUNTY, S.C. ( WIS /Gray News) - Two teens arrested in connection to a shooting that injured nearly a dozen people in South Carolina have been released on bond, officials say. 1449 Adderley v. Florida, 385 U.S. 39 (1966). .1507 The Court further reasoned that the group in power at any moment may not impose penal sanctions on peaceful and truthful discussion of matters of public interest merely on a showing that others may thereby be persuaded to take action inconsistent with its interests. On the one hand, the Court celebrated anonymity. The five-to-four majority concluded that on balance[t]he dangers of distribution can so easily be controlled by traditional legal methods, leaving to each householder the full right to decide whether he will receive strangers as visitors, that stringent prohibition can serve no purpose but that forbidden by the Constitution, the naked restriction of the dissemination of ideas.1. In Zwickler v. Koota, 389 U.S. 241 (1967), the Court directed a lower court to consider the constitutionality of a statute which made it a criminal offense to publish or distribute election literature without identification of the name and address of the printer and of the persons sponsoring the literature. . and Riley v. National Federation of the Blind.5 Footnote487 U.S. 781 (1988). In Illinois ex rel. Message. While it may not seem like much, this is the best action that you can personally take to deter solicitors. John R. Vile. It was in a labor case that the Court first held picketing to be entitled to First Amendment protection.1506 Striking down a at prohibition on picketing to inuence or induce someone to do something, the Court said: In the circumstances of our times the dissemination of information concerning the facts of a labor dispute must be regarded as within that area of free discussion that is guaranteed by the Constitution. Offers FREE consultation! Specifically, Justice Kennedy, writing for the Court, observed that, [w]hile in the past there may have been difficulty in identifying the most important places (in a spatial sense) for the exchange of views, today the answer is clear. A privacy rationale was rejected, as just as much intrusion was likely by permitted as by non-permitted solicitors. Such a demonstration . The language subjected the defendant to criminal liability under a standard so indefinite that police, court, and jury were free to react to nothing more than their own preferences for treatment of the ag.1605, The First Amendment was the basis for reversal in Spence v. Washington,1606 which set aside a conviction under a statute punishing the display of a United States ag to which something is attached or superimposed; Spence had hung his ag from his apartment window upside down with a peace symbol taped to the front and back. ACLU of Pennsylvania. 1447 E.g., Schneider v. Town of Irvington, 308 U.S. 147, 163 (1939); Kunz v. New York, 340 U.S. 290, 293 (1951). Sometimes burglars will knock on a door, to see if someone is home, prior to breaking in. As interpreted, the ordinance banned only picketing that targeted a single residence, and it is unclear whether the Court would uphold a broader restriction on residential picketing.1526. However, the First Amendment to the U.S. Constitution states that Congress shall make no law respecting an establishment of religion or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press; or the right of the people peaceably to assemble, and to petition the Government for a redress of grievances.. In each Congress from the 104th through the 109th (1995 2006), the House passed such a proposal, but the Senate either rejected it or did not vote on it. We are of the opinion that the purpose to keep the streets clean and of good appearance is insufficient to justify an ordinance which prohibits a person rightfully on a public street from handing literature to one willing to receive it. 1489 American Library Association, 539 U.S. at 199; see also id. Without this statement, the seller cannot require payment if the consumer takes action to cancel the contract. Schaumburg was extended in Secretary of State v. Joseph H. Munson Co.,4 Footnote467 U.S. 947 (1984). The Supreme Court has repeatedly ruled that many laws that restrict solicitation are unconstitutional, though privately posted signs are a legitimate way to tell salespeople and other solicitors to leave you alone. This article was originally published in 2009. http://mtsu.edu/first-amendment/article/1106/%60door-to-door%60-solicitation, The Free Speech Center operates with your generosity! 1480 Perry Educ. 1579 Grayned v. City of Rockford, 408 U.S. 104 (1972). The Supreme Court has often affirmed the reasonableness of time, place, and manner restrictions on speech in the door-to-door context. Yet the Court upheld a breach of the peace conviction of a speaker who refused to cease speaking upon the demand of police who feared imminent violence. 1593 E.g., Saia v. New York, 334 U.S. 558 (1948); Kovacs v. Cooper, 336 U.S. 77 (1949). In Hill v. Colorado,1554 the Court upheld a Colorado statute that made it unlawful, within 100 feet of the entrance to any health care facility, to knowingly approach within eight feet of another person, without that persons consent, for the purpose of passing a leaet or handbill to, displaying a sign to, or engaging in oral protest, education, or counseling with such other person.1555 This decision is notable because it upheld a statute, and not, as in Madsen and Schenck, merely an injunction directed to particular parties. Hand delivery of advertisements is cheaper than mailing, but it is still a common form of junk mail. . The Court found the statute to be a content-neutral time, place, and manner regulation of speech that reects an acceptable balance between the constitutionally protected rights of law-abiding speakers and the interests of unwilling listeners . Please type or print clearly. The number is 799-7100 in Richland or Lexington Counties, and 1-800-868-2284 from other parts of the state. 1448 Cox v. Louisiana, 379 U.S. 536, 555 (1965). Consumers are often persuaded or pressured by a skillful and convincing salesperson to make a purchase. 3:45 PM: We've been meaning to publish another reminder about the door-to-door-soliciting laws, . (Peddling is different from "soliciting.") 19. (AP Photo/Charles E. Knoblock, used with permission from the Associated Press), is a professor of political science and dean of the Honors College at Middle Tennessee State University. Chapter 501 CONSUMER PROTECTION Entire Chapter. You're all set! Real questions from people like you. Indeed, it can be assumed that the First Amendment permits a State to enact specific, narrowly tailored laws that prohibit a sex offender from engaging in conduct that often presages a sexual crime, like contacting a minor or using a website to gather information about a minor. Id. Search for lawyers by reviews and ratings. Job specializations: Sales. In this photo, a sign informs motorists of the solicitation guidelines in Stratton. 1501 Hudgens v. NLRB, 424 U.S. 507 (1976). Posted on Nov 29, 2017. 1607 418 U.S. at 40811, 41213. 1587 A fee of up to 20% of collected receipts was deemed reasonable, a fee of between 20 and 35% was permissible if the solicitation involved advocacy or the dissemination of information, and a fee in excess of 35% was presumptively unreasonable, but could be upheld upon one of two showings: that advocacy or dissemination of information was involved, or that otherwise the charitys ability to collect money or communicate would be significantly diminished. (a) Acceptance of money, check, negotiable instrument or other consideration.- (1) When making a door-to-door solicitation, a solicitor may not accept or receive, at the time the solicitation is made, any money, check, or other negotiable instrument, or any other consideration. In order for the consumer to have the right to cancel the contract, the sale must be either a credit transaction in which the seller extends credit to the buyer, or else a sale, lease or rental of consumer goods or services with a purchase price of more than $25. 1472 In Shuttlesworth v. City of Birmingham, 394 U.S. 147 (1969), the Court reaffirmed the holdings of the earlier cases, and, additionally, both Justice Stewart, for the Court, id. 487 U.S. at 800. Therefore we do not pass on the validity of an ordinance limited to these or any other supposed evils.1569, Talleys anonymity rationale was strengthened in McIntyre v. Ohio Elections Commn,1570 invalidating Ohios prohibition on the distribution of anonymous campaign literature. D-1753-05, 8-15-05) (e) Penalties. Only Justice Black joined the Roberts opinion, but only Justices McReynolds and Butler dissented from the result. at 151; Jones v. Opelika, 316 U.S. 584, 602 (1942) (Chief Justice Stone dissenting), adopted per curiam on rehearing, 319 U.S. 103 (1943). E.g., American Socy of Mech. The Court did not consider the Internets status as a forum for free speech, but observed that the Internet constitutes a vast platform from which to address and hear from a world-wide audience of millions of readers, viewers, researchers, and buyers. However, the reason the Courts have ruled that anti-solicitation ordinances violate the First Amendment is because the decision of whether to listen to a solicitor or not is ultimately the individual homeowners decision! we schedule appointments with the customer when we call them if they win to see our product. Such use of the streets and public places has from ancient times, been a part of the privileges, immunities, rights, and liberties of citizens. Although this opinion was not itself joined by a majority of the Justices, the Court subsequently endorsed the view in several opinions.1447, The Roberts view was called into question in the 1960s, however, when the Court seemed to leave the issue open,1448 and when a majority endorsed an opinion by Justice Black asserting his own narrower view of speech rights in public places.1449 Later decisions restated and quoted the Roberts language from Hague, and that is now the position of the Court.1450 Public streets and parks,1451 including those adjacent to courthouses1452 and foreign embassies,1453 as well as public libraries1454 and the grounds of legislative bodies,1455 are open to public demonstrations, although the uses to which public areas are dedicated may shape the range of permissible expression and conduct that may occur there.1456 Moreover, not all public properties are public forums. The ruling came in a case in which a union of employees engaged in an economic strike against one store in a shopping center was barred from picketing the store within the mall. In McCullen v. Coakley, the Court retained a content-neutral analysis similar to that in Hill, but nonetheless struck down a statutory 35-foot buffer zone at entrances and driveways of abortion facilities.1558 The Court concluded that the buffer zone was not narrowly tailored to serve governmental interests in maintaining public safety and preserving access to reproductive healthcare facilities, the concerns claimed by Massachusetts to underlie the law.1559 The opinion cited several alternatives to the buffer zone that would not curtail the use of public sidewalks as traditional public fora for speech, nor significantly burden the ability of those wishing to provide sidewalk counseling to women approaching abortion clinics. Meyer v. Grant, 486 U.S. 414 (1988) (criminal penalty on use of paid circulators to obtain signatures for ballot initiative suppresses political speech in violation of First and Fourteenth Amendments). 1509 Milk Wagon Drivers Union v. Meadowmoor Dairies, 312 U.S. 287 (1941). at 81314. 1454 Brown v. Louisiana, 383 U.S. 131 (1966) (sit-in in library reading room). See also Larson v. Valente, 456 U.S. 228 (1982) (state law distinguishing between religious organizations and their solicitation of funds on basis of whether organizations received more than half of their total contributions from members or from public solicitation violates the Establishment Clause). Does the First Amendment Protect Protestors? The examples are many of the application by this Court of the principle that certain forms of conduct mixed with speech may be regulated or prohibited.1523, The Court must determine, of course, whether the regulation is aimed primarily at conduct, as is the case with time, place, and manner regulations, or whether instead the aim is to regulate the content of speech. To the contention that liability could be imposed on store watchers and on a group known as Black Hats who also patrolled stores and identified black patronizers of the businesses, the Court did not advert to the signal theory. The First Amendment Encyclopedia, Middle Tennessee State University (accessed May 01, 2023). 1488 539 U.S. 194, 20506 (2003) (We have rejected the view that traditional public forum status extends beyond its historic confines. The doctrines surrounding traditional public forums may not be extended to situations where such history is lacking. (quoting Ark. In Lovell v. City of Griffin (1938) and Schneider v. State (1939), the Court struck down ordinances requiring Jehovahs Witnesses and others to obtain the city managers permission prior to engaging in door-to-door solicitations. 1574 City of Ladue v. Gilleo, 512 U.S. 43 (1994). In Watchtower Bible & Tract Socy v. Village of Stratton, 536 U.S. 150, 166 (2002), concern for the right to anonymity was one reason that the Court struck down an ordinance that made it a misdemeanor to engage in door-to-door advocacy without first registering with the mayor and receiving a permit. The precedent established by the case is not clear, however, because the Court has extended increased protection to commercial speech in more recent decisions. Hunter, Howard O., and Polly J. There are appropriate public remedies to protect the peace and order of the community if appellants speeches should result in disorder and violence. Id. 1599 West Virginia State Bd. Civil Liberties Union, 521 at 868); see also id. Maybe. The holding was on a much narrower basis, but in dictum the Court said: The court below has mistakenly derived support for its conclusions from the evidence produced at the trial that appellants religious meetings had, in the past, caused some disorder. But cf. Are You Buying or Selling a Home in an HOA? Full Time position. . "It was getting a lot of the neighborhoods upset there was a lot of issues and just general problems with it and it was time for is to update that," Brand said. The Court was careful to point out, however, that its opinion should not be read as barring states from enacting laws more specific than that of North Carolina, noting that [s]pecific criminal acts are not protected speech even if speech is the means for their commission. Id. If solicitors ignore your posted sign, your knowledge of local laws will help you turn away or prevent any unwanted visitors, although you may still need to report them to local authorities. (AP Photo/Gary Tramontina, used with permission from the Associated Press), The Supreme Court has often affirmed the reasonableness of time, place, and manner restrictions in the door-to-door context. . Specifically, the Court held that, to preserve First Amendment rights, targeted measures, such as injunctions, enforcement of anti-harassment ordinances, and use of general crowd control authority, as needed, are preferable to broad, prophylactic measures.1560, Different types of issues were presented by Hurley v. Irish-American Gay Group,1561 in which the Court held that a states public accommodations law could not be applied to compel private organizers of a St. Patricks Day parade to accept in the parade a unit that would proclaim a message that the organizers did not wish to promote. United States v. Grace, 461 U.S. 171 (1983). Communication of political, economic, social, and other views is not accomplished solely by face-to-face speech, broadcast speech, or writing in newspapers, periodicals, and pamphlets. There is an exception to the right to cancel a door-to-door credit sale, or home solicitation contract. 1455 Edwards v. South Carolina, 372 U.S. 229 (1963); Jeanette Rankin Brigade v. Capitol Police Chief, 342 F. Supp. 1521 372 U.S. at 235. If a homeowner really wants to avoid the hassle of dealing with bothersome knocks on the door, a No Trespassing sign wields more power than No Solicitation. If privately owned property, the HOA should be able to ban such activity by non-members under basic trespassing principles. But, to the degree that these actions are intended to communicate a point of view, the First Amendment is relevant and protects some of them to a great extent. . In this photo, Vice President Walter Mondale, right, does some door-to-door campaigning in Chicagos in 1980. InIllinois ex rel. The Court also voided an injunction against a protest meeting that was issued ex parte, without notice to the protestors and with, of course, no opportunity for them to rebut the representations of the seekers of the injunction. 512 U.S. at 762. Similarly upheld were noise restrictions designed to ensure the health and well-being of clinic patients. 1534 In evaluating the permissibility of government regulation in this context that has an incidental effect on expression, the Court applied the standards of United States v. OBrien, which permits a regulation if it is within the constitutional power of the Government; if it furthers an important or substantial governmental interest; if the governmental interest is unrelated to the suppression of free expression; and if the incidental restiction on alleged First Amendment freedoms is no greater than is essential to the furtherance of that interest. 458 U.S. at 912, n.47, quoting OBrien, 391 U.S. 367, 37677 (1968) (footnotes omitted). Legally reviewed by Laura Temme, Esq. Door-to-Door Complaint. See also Youngdahl v. Rainfair, 355 U.S. 131, 139 (1957) (indicating that, where violence is scattered through time and much of it was unconnected with the picketing, the state should proceed against the violence rather than the picketing). In both the House and the Senate these measures failed to receive the necessary two-thirds vote.1615, 1444 Commonwealth v. Davis, 162 Mass. Encyclopedia Table of Contents | Case Collections | Academic Freedom | Recent News, Door-to-door solicitation can lead to clashes between First Amendment free expression and homeowners privacy rights. If you do not wish for solicitors to knock on your door, you may consider buying a no soliciting sign or a no trespassing sign. A restriction on carrying signs or placards on the grounds of the Supreme Court is unconstitutional as applied to the public sidewalks surrounding the Court, since it does not sufficiently further the governmental purposes of protecting the building and grounds, maintaining proper order, or insulating the judicial decisionmaking process from lobbying. "Yes, Door-to-Door Canvassing Is Protected Speech." See alsoLarson v. Valente,456 U.S. 228 (1982)(state law distinguishing between religious organizations and their solicitation of funds on basis of whether organizations received more than half of their total contributions from members or from public solicitation violates the Establishment Clause). Definition: "home solicitation sale". The county does not regulate hours for door-to-door sales, but Captain Michael Nunn with Florence County Sheriff's Office said people who live in the county have also complained about over aggressive salesmen. On any given day, door-to-door solicitors target Central Texas neighborhoods to make a sale. Id. 121168, slip op. . You are not required to open your door to people you do not know. If it says "no solicitation," it also means that you are not given permission to enter onto the property to put up flyers. Post a free question on our public forum. 2 South Salisbury St . 1473 The only precedent is Kunz v. New York, 340 U.S. 290 (1951). These cases were decided by the Court in a manner that indicated an effort to begin to resolve the standards of First Amendment protection of symbolic conduct. In Smith v. Goguen,1604 a statute punishing anyone who publicly . at 675. (1) Any person who engages in door-to-door solicitation in violation of this Section shall be subject to a fine of $400 for each such violation, each day in which said violation occurs constituting a new offense. A rationale of prevention of fraud was unavailing, as it could not be said that all associations that spent more than 25% of their receipts on overhead were actually engaged in a profit-making enterprise, and, in any event, more narrowly drawn regulations, such as disclosure requirements, could serve this governmental interest. . . In this photo, state Sen. Cheryl Hooker, left, campaigns door-to-door with Gov. Then, the Court formally overruled Logan Valley Plaza, holding that shopping centers are not functionally equivalent to the company town involved in Marsh.1501 Suburban malls may be the new town squares in the view of sociologists, but they are private property in the eye of the law. See National Socialist Party v. Village of Skokie, 432 U.S. 43 (1977). 1537 458 U.S. at 91829, relying on a series of labor cases and on the subversive activities association cases, e.g., Scales v. United States, 367 U.S. 203 (1961), and Noto v. United States, 367 U.S. 290 (1961). . . Madigan v. Telemarketing Assocs., 538 U.S. 600 (2003), Watchtower Bible & Tract Socy v. Village of Stratton. 1524 Edwards v. South Carolina, 372 U.S. 229 (1963); Cox v. Louisiana, 379 U.S. 536 (1965); Gregory v. City of Chicago, 394 U.S. 111 (1969); Bachellar v. Maryland, 397 U.S. 564 (1970). . 1457 United States Postal Serv. Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press; or the right of the people peaceably to assemble, and to petition the Government for a redress of grievances. Compare Forbes, 523 U.S. at 679 (reject[ing] the view that traditional public forum status extends beyond its historic confines [to a public television station]) with Reno v. ACLU, 521 U.S. 844, 85153 (1997) (recognizing the communicative potential of the Internet, specifically the World Wide Web). Putnam Pit, Inc. v. City of Cookeville, 221 F.3d 834, 843 (6th Cir. 1611 The Flag Protection Act of 1989, Pub. In United States v. Kokinda, a majority of Justices, who ultimately upheld a ban on soliciting contributions on postal premises under the reasonableness review governing nonpublic fora, could not agree on the public forum status of a sidewalk located entirely on postal service property.1485 Two years later, in International Society for Krishna Consciousness, Inc. v. Lee, the Court similarly divided as to whether non-secured areas of airport terminals, including shops and restaurants, constitute public fora.1486 A five-Justice majority held that airport terminals are not public fora and upheld regulations banning the repetitive solicitation of money within the terminals.1487, A decade later, the Court considered the public forum status of the Internet. Please, In Watchtower Bible and Tract Society v. Village of Stratton (2002), the Supreme Court struck down a law in Stratton, Ohio, that required anyone going door to door to register with authorities and carry a permit. Instead, the placement of a permanent monument in a public park is best viewed as a form of government speech and is therefore not subject to scrutiny under the Free Speech Clause. Pleasant Grove City, Utah v. Summum, 555 U.S. at 464.. 1477 Perry Educ. v. Barnette, 319 U.S. 624, 632 (1943). ACLU of Pennsylvania. See also Collin v. Smith, 447 F. Supp. "This is a very old statute, but it still applies its good law and it provides protection for folks if they feel threatened or intimidated," Nunn said. 501.022 Home solicitation sale; permit required.. Subsequently, the Court vacated, over the dissents of Chief Justice Burger and Justices White, Blackmun, and Rehnquist, two convictions for burning ags and sent them back for reconsideration in the light of Goguen and Spence. Prior to July 1, 2015, door to door solicitors were required to obtain a City of Raleigh business license and carry a copy with them. Martin v. City of Struthers, 319 U.S. 141, 147 (1943), Hynes v. Mayor of Oradell, 425 U.S. 610, 61617 (1976), Village of Schaumburg v. Citizens for a Better Environment, 444 U.S. 620 (1980). simply because it may embarrass others or coerce them into action.1532 The boycott had a disruptive effect upon local economic conditions and resulted in loss of business for the merchants, but these consequences did not justify suppression of the boycott. The governments underlying interest, characterized by the Court as resting upon a perceived need to preserve the ags status as a symbol of our Nation and certain national ideals,1613 still related to the suppression of free expression. Colorado, 1554 the Court upheld a Colorado statute that made it unlawful, within 100 feet of the entrance to any health care facility, to "knowingly approach" within eight feet of another person, without that person's consent, "for the purpose of passing a leaet or handbill to, displaying a sign to, or engaging in oral protest, education, or 1481 City Council v. Taxpayers for Vincent, 466 U.S. 789 (1984) (upholding an outright ban on use of utility poles for signs). Assn v. Perry Local Educators Assn, 460 U.S. 37 (1983) (interschool mail system); ISKCON v. Lee, 505 U.S. 672 (1992) (publicly owned airport terminal).

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