Tyler v. Kingston, No. 22-664 (2d Cir. 2023)
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Plaintiffs brought a First Amendment challenge to the City of Kingston’s prohibition against bringing signs and posters into public meetings of the Common Council held at Kingston City Hall. The City moved to dismiss, arguing that Common Council meetings are limited public fora in which the City is permitted to reasonably restrict speech that undermines the purpose for which the forum had been opened. The district court granted the City’s motion, noting that government entities are permitted to regulate the manner in which the public participates in limited public fora. The district court concluded that Plaintiffs had not adequately alleged that the City’s sign prohibition was unreasonable in light of the potential disruption or distraction that signs at Common Council meetings might pose.
The Second Circuit affirmed. The court held that the Complaint itself and common sense offer a satisfactory rationale for the City’s sign prohibition, which undermines Plaintiffs’ assertions of unreasonableness. To be sure, there may be cases where restrictions on the form or manner of speech—including the use of signs—in a limited public forum would be unreasonable, but Plaintiffs have not pled such facts here.
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