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2019 Goal Setting Session Packet
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2019 Goal Setting Session Packet
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1/2/2019 10:43:02 AM
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PRESENTATION TITLE (EDIT ON MASTER)Free Speech in Public Meetings: Relevant Case Law•Public Forum Doctrine–In a “true public forum” such as a sidewalk or park, limitations on speech must be very narrow–Reasonable time, place, or manner restrictions are valid as long as they are content-neutral, narrowly tailored to serve a significant government interest, and leave open alternative channels for communication•Clark v. Cmty. for Creative Non-Violence, 468 U.S. 288, 293 (1984)•Limited public forum–The government is not required to allow persons to engage in every type of speech when it creates a limited public forum for a specific purpose, as long as limits on speech are content-neutral and reasonable•Good News Club v. Milford Cent. Sch., 533 U.S. 98, 106 (2001)•Is a City Council meeting a “limited public forum”?–In some jurisdictions, clearly yes•White v. Norwalk, 900 F.2d 1421 (9th Cir. 1990) (city council can limit discussion to the topic at hand)–In the 8thCircuit, it’s less clear-cut, but likely yes•Green v. Nocciero, 676 F.3d 748, 753 (8th Cir. 2012) (Court held in dicta that a school board meeting is a limited public forum, and the Board can reasonably restrict access based on the subject matter of the speech)7
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