In Knotts v. City of Cuyahoga Falls. (ND OH, March 31, 2026), an Ohio federal district court upheld the application of a noise ordinance to anti-abortion sidewalk counselors who engage in sidewalk advocacy based on their religious beliefs. The court rejected plaintiffs' free speech, free exercise, and vagueness challenges to the ordinance, saying in part:
The Court notes that on its face 1) the Ordinance does not regulate speaker identity, but rather the amplification of the speaker, 2) it does not regulate the content of speech, but rather the amplification of said speech, and 3) the Ordinance exempts certain locations holding specific events (concerts, live outdoor musical or theatrical performances) from amplification restrictions, not content. For example, under this Ordinance, a religious organization hosting a theatrical performance on its property is exempt from the amplification restrictions whether that performance is pro-life or pro-choice. The Ordinance is content neutral. ...
The Ordinance applies to everyone, and does not regulate nor mention any religious activity, creed or affiliation..... It does not distinguish among religions or between religion and non-religion. Accordingly, it is neutral and generally applicable.
Plaintiffs summarily assert that the Ordinance violates their first Amendment right to free exercise as it applies to them.... Plaintiffs explain that they “hold sincere religious convictions that compel them to engage in sidewalk advocacy to save the lives of the unborn, which they express through amplified speech.”... However, “‘a generally applicable law that incidentally burdens religious practices usually will be upheld.’”
... [T]he burden does not infringe “free exercise unless it places a substantial burden on a central religious belief or practice[.]” There is no such burden here. Plaintiffs were not denied the right to speak on their religious views or otherwise express their views, they merely were not permitted to engage in amplified speech over the complaint of neighbors....
