In the 1980 case Heffron v. International Society for Krishna Consciousness, Inc., the U.S Supreme Court ruled in favor of Minnesota State Agricultural Society Board of Managers (MSASBM), upholding a state rule that restricted solicitation and distribution of literature to designated booths at the Minnesota State Fair. The International Society for Krishna Consciousness (ISKCON) had challenged this rule, arguing it violated their First Amendment rights to freedom of speech and religion as they sought to distribute religious materials throughout the fairgrounds. However, the court held that while ISKCON's activities were protected under First Amendment rights, these could be subject to reasonable restrictions in order to maintain orderly movement and control congestion within public spaces like a state fairground. Therefore, requiring groups such as ISKCON to operate from specific locations did not infringe upon their constitutional rights but was rather an acceptable limitation necessary for maintaining public safety and order.

In the dissenting opinion for Heffron v. International Society for Krishna Consciousness, Justice Brennan argued that the Minnesota State Fair's rule requiring all sales and solicitations to occur in designated booths was unconstitutional as it violated First Amendment rights of free speech. He contended that this regulation did not serve a significant government interest nor was it narrowly tailored to achieve such an interest. The fairgrounds were a public forum where diverse social, political, and religious groups should be allowed to freely express their views without being confined to specific areas. Furthermore, he believed there were less restrictive means available for managing crowd control and maintaining order at the fair than limiting expressive activity only within assigned booths. Thus, he concluded that this restriction on freedom of expression could not withstand constitutional scrutiny under First Amendment jurisprudence.