Advocacy organization and two of its members brought action against city, alleging California statute making it a misdemeanor to disrupt meetings was unconstitutional, both on its face and as applied, under the First and Fourteenth Amendments. The United States District Court granted city’s motion. Plaintiffs appealed.
The Court of Appeals held that:
- Statute governing disruption of meetings did not apply to disruptive conduct during public meetings of electors regarding public questions;
- Statute making it a misdemeanor to disrupt meetings was not a content-based restriction on speech; and
- Statute making it a misdemeanor to disrupt meetings was narrowly tailored to substantial state interest.