International Society for Krishna Consciousness v. Lee - Impact

The ruling represented a more narrow interpretation of the public forum doctrine than had been made in the past. Such an interpretation was in keeping with the Court's more conservative leanings following the appointments of justices Kennedy, O'Connor, Souter, and Thomas by Presidents Ronald Reagan and George Bush during the 1980s. This case did not represent an unmitigated victory for the port authority, however. Despite its more narrow interpretation of the public forum doctrine the Court relied heavily on practical considerations, in this case relieving pedestrian congestion in airport terminals, in reaching its decision. As such, it was unwilling to allow the port authority to restrict speech under circumstances where exercise of such speech would not pose an undue inconvenience to air travelers. For this reason, the Court agreed with the court of appeals in a parallel case, Lee v. International Society for Krishna Consciousness, that the port authority could not ban distribution of literature within its terminals.