In the case of Campbell v. City of Olney, 1922, the U.S Supreme Court ruled in favor of the city's right to enforce a local ordinance that prohibited circuses from operating within its boundaries. The plaintiff, Mr. Campbell who was a circus owner argued that this law violated his Fourteenth Amendment rights by depriving him of property without due process and denying him equal protection under the laws. However, Justice Holmes delivered an opinion stating that there is no constitutional right to operate a circus and cities have broad powers to regulate businesses for public health and safety reasons or even aesthetic considerations. Therefore, it was held that such ordinances do not violate any federal constitutional rights.

The dissenting opinion in the Campbell v. City of Olney case argued that the city's ordinance, which prohibited advertising vehicles from using its streets without a permit, was not an unreasonable exercise of police power and did not infringe upon constitutional rights. The justice believed that cities have the right to regulate their own streets for safety and convenience purposes. They also noted that such regulations are necessary due to increasing traffic congestion caused by various types of vehicles including those used for advertising purposes. Therefore, they disagreed with the majority ruling that found this ordinance unconstitutional on grounds it violated freedom of speech or press as protected under Fourteenth Amendment.