Following the Seventh Circuit’s invalidation of Springfield’s anti-panhandling ordinance, the city amended its municipal code’s provisions regarding panhandling.  The new code provisions prohibited panhandling “[p]anhandling while at any time before, during, or after the solicitation knowingly approaching within five feet of the solicited person,” and defined “panhandling” as a “vocal appeal” for an immediate donation.  Distinguishing the city’s ordinance from the Colorado law at issue in the 2000 Supreme Court case of Hill v. Colorado, the district court found that the new code provisions were content based.  Because the ordinance applied only in cases where the requestor asked for an immediate donation of money or other gratuity while within five feet of the solicited person, the district court found the ordinance content based and concluded that the city could not meet strict scrutiny.

Norton v. City of Springfield, No. 15-3276, slip op., 2015 WL 8023461 (C.D. Ill. Dec. 4, 2015)