The post-Reed assault on panhandling bans continued when a federal court in Massachusetts held that the City of Worcester’s ordinance prohibiting aggressive panhandling was content based and unconstitutional.  In 2014, in an opinion authored by retired Supreme Court Justice David Souter, the First Circuit Court of Appeals held that Worcester’s anti-panhandling ordinance was content neutral and constitutional.  Following Reed, the Supreme Court granted a cert petition in the case, vacated the First Circuit decision, and remanded the matter back to the court of appeals.  The First Circuit then vacated its opinion and judgment and remanded to the district court for further consideration in light of Reed.  Back at the district court, the ordinances—which defined “begging” or “panhandling” as “asking for money or objects of value with the intention that the money or object be transferred at that time and at that place” and also defined “aggressive manner”—were found to be content based, since they applied to particular speech based on the content of the speech.  The court went on to find that the ordinance was not narrowly tailored, as it was not the least restrictive means of achieving the governmental interest at stake.  
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