SW Legal studies in Business

Ordinance Restricting Immediate Solicitation of Money at L.A. Airport Upheld

California Supreme Court held that an ordinance issued by the City of Los Angeles for the L.A. Airport that prohibits people from soliciting for donations at the airport is valid.

Topic Constitutional Law
Key Words

First Amendment; Free Expression; Restrictions; Solicitation

C A S E   S U M M A R Y

The City of Los Angeles enacted an ordinance prohibiting persons from soliciting funds at Los Angeles International Airport (LAX). The International Society for Krishna Consciousness of California sought an injunction against enforcement of the ordinance in federal district court. The court granted the injunction, holding that the ordinance violated the First Amendment. The City appealed. The federal appeals court asked the California Supreme Court: Is LAX a public forum under the Liberty of Speech Clause of the California Constitution? If so, does the ordinance violate the California Constitution?


Question answered. The City ordinance prohibiting the solicitation and immediate receipt of funds at LAX is a valid time, place, and manner restriction of free expression, under the free speech provision of the state constitution. The restriction was narrowly tailored and is content neutral. Even if public areas of the airport were a public forum, and even though the ordinance was not limited to peak hours or particular locations within the airport, the ordinance allowed other forms of free expression, including the solicitation of future donations. Since the ordinance is valid, there is no need to determine if LAX is a public forum.


International Society for Krishna Consciousness of California v. City of Los Angeles, ---Cal.Rptr.3d--- (2010 WL 1071387, Sup. Ct., Calif., 2010)

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