Facts of the Case

The Board of Airport Commissioners of Los Angeles adopted an ordinance which prohibited all "First Amendment activities" in the Los Angeles International Airport (LAX). Alan Snyder, a minister with Jews for Jesus, was instructed by an airport officer to refrain from distributing free religious literature on a walkway in the central terminal of LAX.

Question

Did the Los Angeles ordinance violate the First and Fourteenth Amendments of the Constitution?

Conclusion

Yes. Using the "First Amendment overbreadth doctrine," which allows an individual to challenge a statute on its face which is potentially threatening to others, the Court found that the ordinance violated the Constitution. Justice O'Connor argued that the rule was vague, overly broad, and would have effectively prohibited activities such as reading, talking, or wearing expressive shirts or political buttons in the LAX terminal. Allowing such an ordinance, which touched "the universe of expressive activity" in its totality, would have caused LAX to become a "First Amendment Free Zone," according to O'Connor.