Governmental restrictions on political expression in the quintessential public forum are subject to demanding judicial scrutiny. Bans on such speech are almost categorically unconstitutional, and time, place and manner restrictions are valid under the federal analysis only if they are (1) content-neutral, (2) narrowly tailored to serve a significant government interest, and (3) leave open ample alternative channels of communication.
Washington applies an even more stringent test, requiring that the proffered governmental interest be "compelling" rather than merely "significant." The seminal Washington case is Collier v. City of Tacoma. At issue in Collier was a Tacoma ordinance that prohibited the display of political campaign lawn signs on public property more than 60 days prior to the election advertised by the sign. Michael Collier, an underdog congressional candidate who had posted campaign lawn signs in the parking strips located between city streets and sidewalks in violation of the 60 day requirement, challenged Tacoma's regulatory scheme as a free speech violation. The Washington Supreme Court sided with Collier and invalidated the city's pre-election durational limit on campaign lawn signs under the three-prong time, place and manner analysis recited above.
Emphasizing the constitutional protection afforded to political speech in the quintessential public forum, the Collier court rejected Tacoma's proffered justification for the restriction (community aesthetics and traffic safety) as insufficiently "compelling", and concluded that the ordinance was neither narrowly tailored nor allowed adequate alternative channels of communication. Critical to the court's conclusion in Collier was the recognition that small, portable campaign lawn signs represent a practical, cost-effective and highly localized campaign medium for political candidates. Collier reaffirmed the enhanced judicial protection enjoyed by campaign lawn signs in the public forum, and underscored the heightened scrutiny governmental restrictions must endure when regulating communications of this type.
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