## Facts

- A public university adopted a dormitory solicitation policy that initially imposed a total ban on door-to-door solicitation in student residence halls.
- The policy was briefly revised to allow a narrow, time-limited door-to-door campaigning exception for certain student-government candidates, but that exception was repealed before any election occurred under it and was never implemented in practice.
- A student organized on-campus Bible discussions and promoted them by going door to door in dormitories to invite other students.
- After resident complaints, university officials informed the student that door-to-door solicitation violated the dormitory policy and warned of disciplinary consequences.
- Disciplinary charges were initiated but later dismissed for lack of identification evidence.
- The student filed a § 1983 action alleging the solicitation policy violated the First Amendment rights of free speech and free exercise of religion.
- The district court granted summary judgment for the university officials, and the student appealed.

## Issues

1. Whether the dormitory door-to-door solicitation restriction violated the First Amendment free-speech rights of a student engaging in religious invitations, including any claim of content-based discrimination based on a short-lived political-candidate exception.
2. Whether application of the solicitation restriction to religious door-to-door activity violated the First Amendment free-exercise right.

## Decision

- The court of appeals affirmed summary judgment for the defendants.
- The dormitories were treated as a nonpublic forum for purposes of door-to-door solicitation, and the restriction was upheld as reasonable in light of dormitory privacy and order.
- The short-lived political-candidate exception did not establish actionable discriminatory treatment because it was never implemented and was repealed before it operated.
- The policy, as applied, did not suppress speech based on viewpoint and left open other means for the student to communicate on campus.
- The free-exercise claim failed because the restriction was a neutral regulation of conduct in a specific place and did not single out religious practice.

## Legal Principles

- Access to government property for expressive activity depends on forum classification; in a nonpublic forum, restrictions are permissible if reasonable and not viewpoint-based.
- A university may limit door-to-door solicitation in residence halls to protect resident privacy and the orderly operation of dormitory life, while allowing speech through other channels.
- A facial exception that is repealed before any implementation may be insufficient, without concrete differential treatment, to prove unconstitutional favoritism or discrimination in application.
- Neutral regulation of solicitation methods and locations does not violate free exercise when it does not target religious conduct and leaves alternative avenues for religious expression.

## Conclusion

The court upheld the university’s residence-hall door-to-door solicitation ban, concluding that dormitories functioned as a nonpublic forum for such activity, the restriction was reasonable and not viewpoint-based, the brief political-candidate exception did not create operative discrimination, and the policy’s neutral application did not infringe free exercise.


Chapman v. Thomas, 743 F.2d 1056 (4th Cir. 1984)