International Society for Krishna Consciousness, Inc. v. Lee case brief

International Society for Krishna Consciousness, Inc. v. Lee case brief summary
505 U.S. 672 (1992)

CASE SYNOPSIS

Petitioner religious group appealed the order of the United States Court of Appeals for the Second Circuit partially denying petitioner's motion for declaratory relief pursuant to its Right to Free Speech, U.S. Constitutional Amendment I. The religious group sought to prevent respondent police superintendent from enforcing a regulation that limited their solicitation and distribution of literature at an airport.

CASE FACTS
Petitioner religious group sought a declaratory judgment that a regulation limiting distribution of literature and solicitation at an airport to areas outside the terminals violated the Right to Free Speech, U.S. Constitutional Amendment I, and 42 U.S.C.S. § 1983, and sought an injunction preventing respondent police superintendent from enforcing the regulation. The lower court granted petitioner's motion as to distribution of literature, but denied it as to solicitation.

DISCUSSION

• On appeal, the court affirmed, holding that airports were not traditional public forums because their traditional purpose was not to promote the free exchange of ideas but to facilitate air travel. 
• Therefore, the regulation needed only to be reasonable. 
• The regulation was reasonable because it promoted respondent's interest in crowd control and efficient air travel by limiting solicitation to the areas outside of the airport terminals.

CONCLUSION

The court affirmed, holding that an airport was not a traditional public forum, therefore respondent's regulation limiting speech was required to be reasonable. A regulation limiting solicitation to areas outside an airport was reasonable to promote efficient air travel.