The Village of Schaumburg v. Citizens for a Better Environment case in 1979 revolved around the constitutionality of an ordinance that prohibited door-to-door or on-street solicitation by charitable organizations unless such solicitations were used directly for philanthropic purposes, with at least 75% of funds raised going towards these causes. The Citizens for a Better Environment (CBE), whose fundraising activities did not meet this requirement as they also funded litigation and lobbying efforts, challenged the ordinance. The U.S Supreme Court ruled in favor of CBE, stating that the ordinance violated their First Amendment rights to freedom of speech and assembly. The court held that while municipalities have legitimate interests in preventing fraud, protecting residents' privacy and controlling administrative costs associated with permit systems, these interests must be pursued through means less intrusive than direct prohibition on solicitation. It further noted that advocacy was just as important to charities like CBE as more traditional forms of charity work.

In the dissenting opinion for Village of Schaumburg v. Citizens for a Better Environment, Justice Rehnquist argued that the majority's decision to strike down an ordinance requiring charitable organizations to use at least 75% of their donations directly on their cause was misguided. He contended that this requirement did not infringe upon First Amendment rights but rather served as a reasonable regulation designed to prevent fraud and protect citizens from deceptive fundraising practices. Furthermore, he suggested that it is within the purview of local governments like Schaumburg to enact such regulations in order to safeguard public interests. The majority’s ruling, according to him, could potentially undermine these efforts by making it more difficult for municipalities across the country to regulate solicitation activities effectively.