In the 1947 case of Saia v. New York, the U.S. Supreme Court ruled in favor of a Jehovah's Witness who had been denied a permit to use loudspeakers for religious purposes by local authorities in Lockport, New York. The court held that this denial was an unconstitutional infringement on his First Amendment rights to freedom of speech and religion. The city argued that it had enacted its ordinance regulating sound amplification devices to prevent noise disturbances and maintain public order but the court found these reasons insufficiently compelling to justify such a broad restriction on free speech rights. Instead, they suggested less restrictive alternatives could be used like setting limits on volume or restricting use during certain hours.

In the dissenting opinion for Saia v. New York, Justice Frankfurter argued that the majority's decision was an overreach of judicial power and a misinterpretation of First Amendment rights. He contended that local authorities should have discretion in regulating noise within their jurisdictions, including religious speech amplified through loudspeakers. According to him, such regulations do not necessarily infringe upon freedom of speech but rather aim at preventing disturbances and maintaining public order. He emphasized that while free speech is vital to democracy, it does not give individuals unrestricted liberty to use any means or methods they choose without considering potential disruptions or harm caused by them. The justice also expressed concern about courts becoming arbiters on matters better left to legislative bodies with more expertise in dealing with local issues.