In the 1986 case Board of Airport Commissioners of the City of Los Angeles v. Jews for Jesus, Inc., the U.S. Supreme Court unanimously ruled that a resolution banning all "First Amendment activities" at Los Angeles International Airport was unconstitutional. The airport had adopted this policy to prevent congestion and maintain orderly movement in its central terminal area, but it was challenged by Alan Howard Snyder, an employee of Jews for Jesus who distributed free religious literature there. The court held that such a sweeping ban violated freedom of speech as protected under the First Amendment because it covered all manner of expressive activity and did not limit itself to addressing specific problems like congestion or disruption.

In the dissenting opinion for Board of Airport Commissioners of the City of Los Angeles v. Jews for Jesus, Inc., Justice White argued that the majority's decision was too broad and could potentially limit reasonable restrictions on speech in nonpublic forums. He contended that while First Amendment rights are important, they do not supersede all other considerations at a public airport terminal. The resolution center should be able to regulate or ban activities causing congestion or disturbances without violating free speech rights. Furthermore, he believed that an outright ban on "First Amendment activities" was not necessarily unconstitutional if it served significant government interests and left open ample alternative channels for communication.