MARTIN v. STRUTHERS
Martin was a Jehovah's Witness in Struthers, Ohio. She canvassed neighborhoods knocking on doors and ringing doorbells to distribute leaflets promoting a meeting. She was convicted and fined $10 for violating a city ordinance that prohibited a person who was distributing leaflets and other flyers from knocking on doors and ringing doorbells. She appealed her conviction in the Circuit Court of Mahoning County, alleging that the city ordinance violated her First Amendment free speech and free press rights. The Circuit Court upheld the ordinance and her conviction. The Supreme Court of Ohio dismissed her appeal.
Did the city ordinance prohibiting the ringing of doorbells and knocking on doors by a person distributing promotional materials violate the free speech and free press clauses of the First Amendment?
Yes. In a 5-4 decision, the Court reversed the Supreme Court of Ohio and held Struthers' ordinance unconstitutional. In the majority opinion written by Justice Hugo L. Black, the Court acknowledged the city's interest in preventing crime and reducing nuisances. However, alternative solutions, such as trespassing laws, were also available that could achieve the city's purpose. Activities like Martin's were "so clearly vital to the preservation of a free society that, putting aside reasonable police and health regulations of time and manner of distribution, it must be fully preserved." The ordinance was overly restrictive on door-to-door distributors, and therefore unconstitutional.