## Facts

- The City of Struthers, Ohio enacted an ordinance making it unlawful for anyone distributing handbills, circulars, or advertisements to knock, ring doorbells, or otherwise summon residents to the door to receive them.
- Thelma Martin, a Jehovah’s Witness, went door to door in an orderly manner to distribute leaflets advertising a religious meeting.
- Martin was convicted in the city’s Mayor’s Court and fined $10 for violating the ordinance.
- Ohio courts affirmed the conviction, and the Supreme Court of Ohio dismissed her appeal.
- Martin sought review in the U.S. Supreme Court, arguing the ordinance violated constitutional protections for speech and press as applied to religious leafleting.

## Issues

1. Whether a municipal ordinance that forbids door-to-door summons for the purpose of distributing handbills or circulars violates the First Amendment, as applied to the states through the Fourteenth Amendment, when enforced against religious leafleting.
2. Whether a city may categorically bar door-to-door literature distribution to prevent nuisance and crime, rather than using narrower measures that preserve individual household choice.

## Decision

- The Supreme Court reversed, holding the ordinance unconstitutional as applied to Martin’s door-to-door religious distribution of literature.
- The Court ruled, 5–4, that the ordinance invalidly denied freedom of speech and press by broadly prohibiting door-to-door distribution through knocking or ringing.
- The majority emphasized that the ordinance substituted the community’s judgment for the individual householder’s decision whether to receive a speaker.
- The Court acknowledged permissible reasonable time-and-manner regulation but held this ordinance was an overbroad ban on a protected method of communication.
- Justice Murphy concurred, stressing that the restriction also burdened religious practice.
- Dissents argued the ordinance reasonably protected privacy and safety and that local judgments on household repose deserved deference.

## Legal Principles

- The First Amendment protects both the right to distribute literature and the right of residents to receive it.
- A government may impose reasonable regulations on the time and manner of distribution, but it may not adopt a blanket prohibition that suppresses door-to-door advocacy as a channel of communication.
- Crime-prevention and nuisance rationales do not justify broadly eliminating protected expression when narrower tools (e.g., trespass rules or rules respecting posted refusals) can address those concerns.
- Decisions about whether to hear or receive door-to-door messages generally rest with individual householders, not the municipality acting for all residents.

## Conclusion

The Court held that Struthers could not constitutionally ban door-to-door leafleting by prohibiting knocking or ringing to deliver literature; the First and Fourteenth Amendments protect this form of advocacy, subject only to reasonable, narrowly tailored regulation.


Martin v. City of Struthers, 319 U.S. 141 (1943)