Bloomington, Minnesota required door-to-door solicitors to obtain a city-issued license. The regulation defined solicitor in part as “an individual who goes from place-to-place . . . without an invitation from the owner or occupant, for the purpose of: (1) advertising, promoting, selling, leasing, installing or explaining any product, service, organization or cause; (2) seeking donations of money or property on behalf of any nonprofit, political or educational organization or for the purpose of procuring orders for the sale of merchandise or personal services for future delivery or future performance.” A First Amendment challenge was brought by a nonprofit labor organization. The federal district court found that the ordinance’s definition of “solicitor” was facially content based and subject to strict scrutiny. The court held that the ordinance’s crime prevention goals were not a compelling governmental interest, and that the city had not chosen the least restrictive means of preventing crime.
