In the case of City of Ladue v. Gilleo, Margaret P. Gilleo sued the city of Ladue, Missouri after it prohibited her from displaying a sign protesting the Gulf War on her lawn. The city argued that its ordinance banning all residential signs except those falling under one of ten exemptions was necessary to prevent visual clutter and maintain property values. However, Gilleo contended that this violated her First Amendment rights to freedom of speech. In 1993, the U.S Supreme Court ruled in favor of Gilleo in a unanimous decision stating that while cities have a legitimate interest in regulating some forms of communication to avoid problems such as noise and traffic congestion, they cannot ban an entire medium for communication (in this case residential signs). The court held that Ladue's ordinance was too broad and infringed upon residents' free speech rights because there were other ways for the city to achieve its goals without completely prohibiting certain types of expression.

In the dissenting opinion for City of Ladue v. Gilleo, Justice Stevens argued that while he agreed with the majority's ruling in favor of Margaret P. Gilleo's First Amendment rights, he disagreed with their reasoning and approach to reach this conclusion. He criticized the Court for creating a new category of "residential speech" and applying strict scrutiny to it without sufficient justification or precedent. Instead, Stevens suggested that existing jurisprudence on content-neutral time, place, and manner restrictions could have been used to strike down Ladue’s sign ordinance as overly broad without needing to invent a new doctrine or standard of review. Furthermore, he expressed concern about potential implications of this decision on local governments' ability to regulate visual clutter and maintain aesthetic standards in residential areas.