Heffron v. International Society for Krishna Consciousness, Inc.

United States Supreme Court

452 U.S. 640 (1981)

States are permitted to impose reasonable, content-neutral time, place, and manner restrictions on protected speech and religious practices so long as the state is employing the least-restrictive means of protecting a legitimate government interest.

Relevant Facts

The International Society for Krishna Consciousness, Inc. (the plaintiff) sought to freely distribute literature and solicit funds at the 1977 Minnesota State Fair without renting a booth. The Minnesota State Agricultural Society Board of Managers (the defendant) established rules that allowed anyone to walk around the fair talking or proselytizing to people freely, but prohibited the handing out of literature or soliciting funds without a booth rental. The plaintiff argued that the rule violated their First Amendment freedoms of speech and religion. Specifically, the plaintiff argued that the rule suppressed the practice of Sankirtan, a religious ritual requiring its members to distribute or sell religious literature and solicit donations in public places.

The trial court upheld the booth rule as constitutional based on the state’s interest in providing everyone equal access and preventing congestion on the fairgrounds. The Minnesota Supreme Court reversed, reasoning that the booth rule infringed the plaintiff’s right to practice Sankirtan, and that a less-restrictive rule granting the plaintiffs an exemption would protect the state’s interests. The Minnesota fair officials appealed to the United States Supreme Court.

Issue

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Holding & Reasoning

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Concurrence

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Dissent

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Last updated:

December 20, 2020

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Procedural History

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Citations

452 U.S. 640 (1981)