Supreme Court Rules Against Los Angeles Airport Commission’s Ban on First Amendment Activities (Los Angeles, California)

The Supreme Court case *Board of Airport Commissioners of the City of Los Angeles v. Jews for Jesus, Inc.* (1987) addressed the constitutionality of a resolution by the Los Angeles Board of Airport Commissioners that barred all First Amendment activities in the Central Terminal Area of Los Angeles International Airport. Jews for Jesus, Inc., a Messianic Jewish organization, challenged the resolution, arguing it was facially unconstitutional due to its broad and vague language.

The lower courts ruled in favor of Jews for Jesus, finding the resolution unconstitutionally overbroad. The U.S. district court determined the resolution applied to speech in a public forum and was used discriminatorily against the organization. The Ninth Circuit Court of Appeals affirmed this judgment.

In a 5-4 decision, Justice Sandra Day O’Connor wrote for the majority, upholding the lower courts’ rulings. She emphasized that the resolution, on its face, prohibited all protected expression, effectively creating a “First Amendment Free Zone” at LAX. O’Connor noted the resolution’s overbreadth extended to even the most minimal forms of expression, such as conversation or wearing symbolic clothing. She concluded that the resolution could not be saved through judicial interpretation due to its extreme vagueness.

In a separate concurrence, Justice Byron R. White expressed concern that the majority had not resolved whether the airport should be classified as a traditional public forum. He argued the Court should have addressed this issue directly, as it was central to the case.

The ruling reinforced the principle that government restrictions on speech must be narrowly tailored and not overly broad. It highlighted the importance of clarity in legal language to prevent the suppression of constitutional rights. The decision remains a significant precedent in First Amendment law, particularly regarding the regulation of speech in public spaces.

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