Facts of the Case

A Minnesota law allowed the Minnesota Agricultural Society to devise rules to regulate the annual state fair in St. Paul. Minnesota State Fair Rule 6.05 required organizations wishing to sell or distribute goods and written material to do so from an assigned location on the fairgrounds. In other words, walking vendors and solicitors were not allowed. The International Society for Krishna Consciousness challenged the rule, arguing that it restricted the ability of its followers to freely exercise their religious beliefs at the state fair.

Question

May a state, consistent with the First and Fourteenth Amendments, confine religious organizations wishing to sell and distribute religious literature at a state fair to an assigned location within the fairgrounds?

Conclusion

Using the "valid time, manner, and place" criteria which the Court employs to assess government restrictions of First Amendment activities, the Court held that Rule 6.05 did not violate the Constitution. Since the rule was applied equally to all groups wanting to solicit at the fairgrounds, not making restrictions based on the content of a group's message, and because the state had an important interest in "protecting the safety and convenience" of the fair's patrons, Justice White argued that the rule's restrictions were legitimate. Allowing all religious, nonreligious, and commercial groups to move about the grounds distributing literature and soliciting funds would result in "widespread disorder" which would be potentially dangerous to the fair's visitors.