In Langford v. City of St. Louis, Missouri, No. 20-1488, ___ F.4th ___ (July 6, 2021), the U.S. Court of Appeals for the Eighth Circuit held that a St. Louis ordinance prohibiting the obstruction of vehicular and pedestrian traffic was not facially overbroad or unconstitutionally vague, or unconstitutional as applied to the appellee, who was arrested after she participated in a march and attended a rally. The decision hinges in large part on the distinction between conduct and speech.
On Jan. 21, 2017, a massive protest event known as the Women’s March on Washington took place in the nation’s capital. Similar events took place across the world and across the United States, including in St. Louis, Mo. The Women’s March in St. Louis began with a march eastward on Market Street from Union Station to a green space near the entrance of the Gateway Arch. To accommodate the march, which thousands of people attended, the city police department closed Market Street and several cross streets to vehicular traffic.