Law School Case Brief
Heffron v. Int'l Soc'y for Krishna Consciousness - 452 U.S. 640, 101 S. Ct. 2559 (1981)
A state's interest in confining distribution, selling, and fund solicitation activities to fixed locations is sufficient to satisfy the requirement that a place or manner restriction must serve a substantial state interest.
The International Society for Krishna Consciousness, Inc., an organization espousing the views of the Krishna religion, and the head of one of the Society's temples filed suit in a Minnesota state court against Minnesota officials, seeking declaratory and injunctive relief in regard to Rule 6.05, a rule of the Minnesota Agricultural Society, which required any person, group, or firm desiring to sell, exhibit, or distribute printed or written material within the state's fairgrounds during the state fair to do so only from a fixed location. The complainants asserted that the rule violated the First and Fourteenth Amendments to the United States Constitution by suppressing the practice of Sankirtan, a religious ritual that enjoins the Society's members to go into public places to distribute or sell religious literature and to solicit donations for the support of the Krishna religion. The state trial court upheld the constitutionality of the rule, but the Supreme Court of Minnesota reversed, holding that the rule unconstitutionally restricted the Krishnas' practice of Sankirtan and that the state's interest in providing all fair goers and concessionaires with adequate and equal access to each other and in providing a minimum of congestion on the fairgrounds could be served by means less restrictive of the Krishnas' First Amendment rights. The United States Supreme Court granted certiorari.
Did Rule 6.05, a Minnesota state fair rule that required any person to sell, exhibit, or distribute printed or written material only from a fixed location, violate the Constitution?
The Court held that state fair rule did not violate the First and Fourteenth Amendments to the United States Constitution insofar as it required the Society to distribute and sell religious literature and to solicit donations within the fairgrounds during the state fair only at an assigned location, even though application of the requirement limited the religious practices of the organization. According to the Court, the rule was not applied in an arbitrary way and was applied equally to all organizations. The Court averred that the State's interest in confining distribution, selling, and fund solicitation activities to fixed locations was sufficient to satisfy the requirement that a place or manner restriction must serve a substantial state interest. The rule did not exclude the religious organization from the fairgrounds nor did it deny the organization the right to conduct any desired activity at some point within the forum.
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