Watchtower Bible & Tract Soc’y of N.Y., Inc. v. Colombani, No. 13-1605 (1st Cir. 2014)Annotate this Case
In Puerto Rico, the Controlled Access Law (CAL) allows private citizens to protect themselves against violent crimes by maintaining gated residential communities that incorporate public streets. In 2004, two corporations operated by the governing body of the Jehovah’s Witnesses brought suit against municipal defendants alleging that the CAL unconstitutionally infringed on the Jehovah’s Witnesses’ right to engage in door-to-door ministry. The district court established a remedial scheme that attempted to balance the competing interests of the parties. Both the Jehovah’s Witnesses and the municipalities appealed. The First Circuit upheld the district court’s solution but modified it in some aspects, holding that the district court did not abuse its discretion in crafting the remedy at issue.