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Newark, N.J.-A private residential community is a “constitutional actor” that cannot abridge freedom of speech within its borders, an intermediate New Jersey appeals court ruled last week. The court enjoined an East Windsor planned unit development from putting limits on political campaigning, including placement of lawn signs, despite restrictions imposed on residents as a condition of their property ownership. The decision, in Committee for a Better Twin Rivers v. Twin Rivers Homeowners’ Association, No. A-4047-03T2 (N.J. App. Div.), extends a line of state court cases that treat universities, shopping malls and other private institutions like governmental entities when they open their property to public access.

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