ISKCON v. City of Los Angeles, No. 12-56621 (9th Cir. 2014)Annotate this Case
ISKCON appealed the district court's grant of summary judgment in favor of the City of Los Angeles, Los Angeles International Airport (LAX), manager Stephen Yee, and the LAX police chief, on ISKCON's claim that section 23.27(c) of the Los Angeles Administrative Code - which bans continuous or repetitive solicitation for the immediate receipt of funds at LAX, a nonpublic forum - violated the First Amendment. Major international airports have a legitimate interest in controlling pedestrian congestion and reducing the risk of fraud and duress attendant to repetitive, in-person solicitation for the immediate receipt of funds. The court held that the ordinance acts as a reasonable restriction on protected speech under the First Amendment because it was limited in nature and leaves open alternative channels for ISKCON to raise money. Accordingly, the court affirmed the district court's judgment.