The U.S. Supreme Court case International Society for Krishna Consciousness, Inc., and Brian Rumbaugh v. Walter Lee in 1991 revolved around the issue of whether or not airports could prohibit solicitation within their premises. The International Society for Krishna Consciousness (ISKCON), a religious group known for public solicitation of funds, challenged the Port Authority's regulation banning such activities at three major New York City airports on First Amendment grounds. In a split decision, the court upheld that while airport terminals were not traditional public forums where free speech rights are typically protected to their fullest extent, they also did not fall into categories allowing significant restrictions on speech either. Therefore, it was ruled that ISKCON had every right to distribute literature within these spaces but agreed with lower courts' decisions that upholding bans on face-to-face solicitations due to concerns about fraud and duress was reasonable.

In the dissenting opinion for International Society for Krishna Consciousness, Inc., and Brian Rumbaugh v. Walter Lee, Justice Blackmun argued that the majority's decision to uphold restrictions on solicitation within airport terminals was a violation of First Amendment rights. He contended that airports are public forums where individuals should be able to exercise their freedom of speech without undue interference from authorities. According to him, there is no compelling state interest in limiting such activities at an airport terminal beyond what is necessary for maintaining order and ensuring passenger safety. Furthermore, he criticized the majority's reliance on past cases involving schools and military bases as inappropriate comparisons due to significant differences in context between those environments and an airport terminal.