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TO: Kathy Glanzer <br />FROM: Patrick J. Kelly <br />DATE: June 30, 2015 <br />MEMO <br />Non -Commercial Solicitations <br />The issue of non-profit or non-commercial solicitation ordinance must be narrowly tailored to <br />meet the purpose of protecting city residents from unsafe actions and fraud. The Minnesota <br />League of Cities advises that the ordinance cannot significantly burden non-commercial <br />solicitations and its advocacy. There is no bright line how far cities may go when constitutional <br />rights and commercial activity are intermingled. <br />It is recommended when policing the activities of non-commercial advocates, a conservative <br />approach is practical. Buckley v. American Constitutional Law Foundation, Inc,, 525 U.S. 182, <br />119 S,Ct. 636; ACORN v. Golden, Colorado, 744 Fed.2d 739. The League recommends <br />exempting. registration of non-commercial door-to-door activities. The city is attempting to <br />balance and advocate the rights of non-commercial, door-to-door advocates without prohibiting <br />any of their rights. The city is also balancing recent issues concerning safety of neighborhoods. <br />There is no intention or any type of objective concerning this ordinance to require registration for <br />the purpose of limiting activities of non-commercial speech. <br />The city believes that simple registration would serve to meet the legislative interest of the safety <br />and welfare of the residents and the non-commercial advocate. There is no penalty/no • <br />repercussions for non -registration, but a conduit to promote and legitimize non-commercial <br />speech if an advocate is challenged. In addition, Edina and Vadnais Heights have similar <br />requests for registration. <br />