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California Supreme Court Upholds Restrictions on Solicitation at LAX

On March 25, 2010, the California Supreme Court issued an opinion upholding the City of Los Angeles' prohibition on solicitation for the immediate receipt of funds inside the passenger terminals of the Los Angeles International Airport.  The case was part of a longstanding dispute over the City's regulation of expressive activity at LAX.  The court found, "Prohibiting persons from soliciting the immediate receipt of funds at LAX is a narrowly tailored regulation of expressive activity because it is not substantially broader than necessary to address the particular problems caused by requests for the immediate receipt of funds."  In light of this holding, the court declined to consider the question presented to it by the U.S. Court of Appeals for the Ninth Circuit, whether LAX is a public forum under the California Constitution.