Background
Justin Spiehs visited a public library in Lawrence, Kansas, multiple times to display signs and wear shirts with free speech messages. Library staff enforced policies prohibiting disruptive behavior and unauthorized free speech activities, including holding signs, and suspended Spiehs from the library. Spiehs sued, claiming violations of the First Amendment, equal protection, and due process.
The court’s reasoning
The court assumed the library was a designated public forum. In such a forum, the government may impose reasonable time, place, and manner restrictions that are content-neutral, narrowly tailored to serve a significant governmental interest, and leave open ample alternative channels for communication. The library’s interest in providing a quiet environment for reading and studying is significant. Prohibiting signs is narrowly tailored to prevent disturbance to patrons. Spiehs lacked standing for declaratory and injunctive relief because he did not show subjective deterrence, as he intended to return and communicate in the same manner.
We answer yes because the signs could disturb library patrons who are reading or studying.
Spiehs v. Morgan, et al.
What it means going forward
Library officials may enforce policies prohibiting signs and disruptive speech to maintain a quiet environment for study without violating the First Amendment.