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Supreme Court Unanimously Lets Mississippi Preacher Pursue Prospective Challenge to Protest Ordinance

The ruling clarifies that Heck v. Humphrey does not block forward-looking §1983 suits seeking to prevent future enforcement.

Overview

  • Justice Elena Kagan wrote the opinion for a unanimous Court, reviving Gabriel Olivier’s case without deciding whether Brandon’s ordinance is constitutional.
  • Olivier was arrested in 2021 after refusing to move to a designated protest area near the Brandon amphitheater, pleaded no contest, and received a fine and probation.
  • The 2019 ordinance confines demonstrations to a protest zone roughly 265 feet from the venue, limits loudspeakers audible beyond 100 feet, and requires handheld signs.
  • The Court held that because Olivier seeks only an injunction against future enforcement, his suit is not barred by the 1994 Heck v. Humphrey precedent.
  • First Liberty Institute helped represent Olivier, the Justice Department and religious groups backed his right to sue, and municipalities warn the decision could spur more challenges to local regulations.