In the 1946 case of Gospel Army v. Los Angeles et al., the Supreme Court ruled in favor of the city, upholding its right to enforce zoning laws that restricted where charitable organizations could solicit donations and distribute literature. The Gospel Army, a religious organization providing aid to homeless individuals, challenged these restrictions as an infringement on their First Amendment rights to free speech and religion. However, the court found that while such activities were protected under these amendments, they were not immune from regulation for public safety or welfare reasons. Therefore, it was within Los Angeles' power as a municipality to control where solicitation occurred in order to prevent congestion and maintain orderly streets.

In the dissenting opinion for Gospel Army v. Los Angeles et al., Justice Frank Murphy argued that the majority's decision was an infringement on religious freedom and a violation of due process rights. He contended that the city ordinance, which required permits to operate secondhand stores, was being used as a tool to suppress religious activities under the guise of regulating business practices. The Gospel Army, he noted, was not operating a traditional commercial enterprise but rather using sales of donated goods as part of its religious mission to aid those in need. Therefore, it should be exempt from such regulations intended for profit-driven businesses. Furthermore, he criticized how arbitrarily this law had been applied by local authorities against this particular group while other similar organizations were left unregulated - an act he deemed discriminatory and unjustifiable under any standard or interpretation of constitutional law.