Bruni v. City of Pittsburgh, No. 18-1084 (3d Cir. 2019)
Annotate this CasePlanned Parenthood was the site of numerous clashes between opponents and advocates of abortion rights, including bomb threats, vandalism, and blockades. The police deployed an overtime detail to maintain order. After Pittsburgh was declared a financially distressed municipality in 2003, the detail was discontinued. Police were called as needed. The clinic reported an “obvious escalation.” The City Council held hearings on proposed legislation. Many witnesses expounded on the competing interests and expressed a desire to protect both free speech and access to healthcare, including abortions. A member of the police overtime detail attested that the criminal laws were not adequate. The Ordinance states that “[n]o person or persons shall knowingly congregate, patrol, picket or demonstrate” in a 15-foot “buffer zone” outside the entrance of any hospital or healthcare facility. Plaintiffs engage in leafletting and “peaceful . . . one-on-one conversations” conducted “at a normal conversational level and distance” intended to dissuade listeners from obtaining an abortion. The city asserted that the Ordinance applies to this “sidewalk counseling,” The Third Circuit affirmed summary judgment in favor of the city, concluding that the Ordinance does not cover sidewalk counseling and thus does not impose a significant burden on speech. The Ordinance prohibits “congregat[ing],” “patrol[ling],” “picket[ing],” and “demonstrat[ing],” saying nothing about leafletting or one-on-one conversations. Nor does it mention a particular topic or purpose. With respect to the listed activities, the Ordinance is “narrowly tailored to serve a significant governmental interest.”
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