Lovell v. City of Griffin

The fact that Lovell was distributing pamphlets, rather than newspapers or periodicals was irrelevant to the Court. Since the "press" connotes every sort of publication that affords a vehicle of information and opinion, liberty of the press necessarily embraces pamphlets and leaflets. The fact that the ordinance regulated only distribution and not publication also could not save it. Liberty of press includes by necessity liberty to circulate as well as publish. Without circulation, publication would be of little value. In view of the facial unconstitutionality of the ordinance, the Court concluded its opinion by ruling that defendant was not required to apply for a permit under the ordinance in order to challenge the ordinance in answer to the charge against her.