Board of Airport Commissioners of Los Angeles v. Jews for Jesus, Inc.

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1987 United States Supreme Court case

Board of Airport Commissioners of Los Angeles v. Jews for Jesus, Inc., 482 U.S. 569 (1987), was a case in which the United States Supreme Court held that an ordinance prohibiting all "First Amendment activities" in the Los Angeles International Airport was facially unconstitutional due to its overbreadth .

Background

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In July 1984, Howard Snyder, a minister with the organization Jews for Jesus , was distributing religious leaflets in the Central Terminal Area at Los Angeles International Airport. An officer with the Department of Airports told Snyder that his activities violated a resolution adopted by the Board of Airport Commissioners and requested that he leave or be subject to legal action by the City. Snyder left the airport and Jews for Jesus later sued to challenge the constitutionality of the resolution.

Decision of the Supreme Court

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The unanimous opinion of the Court was written by Justice O'Connor . O'Connor wrote that the ordinance "reaches the universe of expressive activity, and, by prohibiting all protected expression, purports to create a virtual 'First Amendment Free Zone' at LAX". The Airport Commissioners argued that the ordinance would only be applied against activities that were related to the airport, but O'Connor pointed out that "wearing of a T-shirt or button that contains a political message" would still fall within the prohibition.

In a brief concurrence, Justice White expressed his concern that the decision did not address the question of whether the airport constituted a public forum .

References

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1. ↑ "L.A. Airport's Free Speech Curb Upset by High Court : 'Jews for Jesus' Win Rights Case" . Los Angeles Times. June 15, 1987. Retrieved July 16, 2020.
2. ↑ Sekulow, Jay; Zimmerman, Erik (2012–2013). "Reflections on Jews for Jesus: Twenty-Five Years Later" (PDF). Regent University Law Review. 25 (1): 1–23. Retrieved July 16, 2020.
3. ↑ Savage, David (June 16, 1987). "LAX Ban on Soliciting Rejected by High Court : Justices Say Rule Goes Too Far in Limiting Free Speech; Larger Question of Exclusion Ignored" . Los Angeles Times. Retrieved July 16, 2020.
4. 1 2 3 "BOARD OF AIRPORT COMMISSIONERS OF the CITY OF LOS ANGELES, et al., Petitioners v. JEWS FOR JESUS, INC. and Alan Howard Snyder, aka Avi Snyder" . LII / Legal Information Institute. Retrieved February 24, 2026.

External links

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• Text of Board of Airport Commissioners of Los Angeles v. Jews for Jesus, Inc., 482 U.S. 569 (1987) is available from: Cornell CourtListener Findlaw Google Scholar Justia Library of Congress Oyez (oral argument audio)

U.S. Supreme Court Freedom of Speech Clause case law

**First Amendment to the United States Constitution **

Unprotected speech

Strict scrutiny

• _Holder v. Humanitarian Law Project _ (2010)
• _Williams-Yulee v. Florida Bar _ (2015)

Overbreadth and
Vagueness doctrines

• _Terminiello v. City of Chicago _ (1949)
• _Smith v. Goguen _ (1974)
• _Board of Airport Commissioners v. Jews for Jesus _ (1987)
• _Minnesota Voters Alliance v. Mansky _ (2018)

Symbolic speech

versus conduct

• _Stromberg v. California _ (1931)
• _United States v. O'Brien _ (1968)
• _Cohen v. California _ (1971)
• _Spence v. Washington _ (1974)
• _Clark v. Community for Creative Non-Violence _ (1984)
• _Dallas v. Stanglin _ (1989)
• _Texas v. Johnson _ (1989)
• _United States v. Eichman _ (1990)
• _Barnes v. Glen Theatre _ (1991)
• _City of Erie v. Pap's A. M. _ (2000)
• _Virginia v. Black _ (2003)

Content-based
restrictions

• _Lamont v. Postmaster General _ (1965)
• _Metromedia, Inc. v. San Diego _ (1981)
• _Boos v. Barry _ (1988)
• _Simon & Schuster, Inc. v. Crime Victims Board _ (1991)
• _R.A.V. v. City of St. Paul _ (1992)
• _Reed v. Town of Gilbert _ (2015)
• _Barr v. American Association of Political Consultants _ (2020)
• _City of Austin v. Reagan National Advertising of Austin, LLC _ (2022)

Content-neutral
restrictions

• _Schneider v. New Jersey _ (1939)
• _United States v. Albertini _ (1985)
• _Renton v. Playtime Theatres, Inc. _ (1986)
• _[Arcara v. Cloud Books, Inc.

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