In response to the Supreme Court's decision in Reed vs. Town of Gilbert, the Seventh Circuit struck down a panhandling ordinance, prohibiting begging for money in the City's historical downtown district in Norton v. City of Springfield. In Reed, the Supreme Court held that a sign code ordinance unconstitutionally regulated the display of street signs by referencing the sign's category (e.g., "ideological signs," or "political signs"). Springfield's ordinance banned oral requests for immediate donations but allowed oral requests for future donation sand signs requesting money (apparently under the theory that the latter was less threatening and impositional). Based on Reed, Norton held that Springfield's panhandling ordinance could not ban certain classes of panhandling. Cities should take note of the Reed and Norton decisions and the impact of their regulatory powers. Regulations categorizing speech by subject matter will be vulnerable to a constitutional challenge
