June 2023 - Parks & Recreation - 26

LAW REVIEW
In the case of Stewart v. City & County of San
Francisco, California, Plaintiffs challenged the
constitutionality of a regulation that required a park
permit for religious events and sound amplification.
Park Permits for Sound Amplification
and Religious Events
By James C. Kozlowski, J.D., Ph.D.
n the case of Stewart v. City & County of San Francisco, California, 2022
U.S. Dist. LEXIS 127346 (N.D. Cal. 6/22/2022), Plaintiffs challenged
the constitutionality of the City and County of San Francisco
Park Code Section 7.03, a regulation that required a park permit for
religious events and sound amplification.
Park Worship Permit
Plaintiffs Alexander Stewart and
Andrew Conway are evangelical
Christians who " want to worship
God on a regular basis. " Plaintiffs
believe in church fellowship
and regular assembly of worship
with fellow Christians. As part of
their worship, Plaintiffs want to
attend weekly worship services
in public parks in San Francisco.
Plaintiffs are both affiliated
with Christ's Forgiveness Ministries
(CFM) in San Francisco,
26 Parks & Recreation | JUNE 2 0 2 3
a non-denominational Christian
ministry that seeks to serve the
world through evangelism and
church planting. Plaintiff Stewart
is an elder with CFM.
CFM gathers
every
Sunday
morning for worship. CFM does
not own any property, so being
able to " access public parks
which are freely accessible and
suitable for worship services is
important for CFM to be able to
carry out its mission of sharing
the gospel of Jesus Christ with
| PARK S ANDRECRE AT ION . OR G
I
others. " CFM's weekly services
usually range from 40 to 70 attendees.
Church services typically
begin with 30 minutes of singing
and playing musical instruments,
followed by testimonies, communion,
offering and a sermon.
CFM uses sound amplification so
that attendees can hear the music
and sermon; without such amplification,
Plaintiffs say they cannot
effectively participate in their
worship services.
Over the course of four months,
Plaintiffs had their church services
interrupted by park rangers,
citing violations of various
sections of Section 7.03. On
January 24, 2021, Plaintiffs started
their church service at San

June 2023 - Parks & Recreation

Table of Contents for the Digital Edition of June 2023 - Parks & Recreation

June 2023 - Parks & Recreation - Intro
June 2023 - Parks & Recreation - Cover1
June 2023 - Parks & Recreation - Cover2
June 2023 - Parks & Recreation - 1
June 2023 - Parks & Recreation - 2
June 2023 - Parks & Recreation - 3
June 2023 - Parks & Recreation - 4
June 2023 - Parks & Recreation - 5
June 2023 - Parks & Recreation - 6
June 2023 - Parks & Recreation - 7
June 2023 - Parks & Recreation - 8
June 2023 - Parks & Recreation - 9
June 2023 - Parks & Recreation - 10
June 2023 - Parks & Recreation - 11
June 2023 - Parks & Recreation - 12
June 2023 - Parks & Recreation - 13
June 2023 - Parks & Recreation - 14
June 2023 - Parks & Recreation - 15
June 2023 - Parks & Recreation - 16
June 2023 - Parks & Recreation - 17
June 2023 - Parks & Recreation - 18
June 2023 - Parks & Recreation - 19
June 2023 - Parks & Recreation - 20
June 2023 - Parks & Recreation - 21
June 2023 - Parks & Recreation - 22
June 2023 - Parks & Recreation - 23
June 2023 - Parks & Recreation - 24
June 2023 - Parks & Recreation - 25
June 2023 - Parks & Recreation - 26
June 2023 - Parks & Recreation - 27
June 2023 - Parks & Recreation - 28
June 2023 - Parks & Recreation - 29
June 2023 - Parks & Recreation - 30
June 2023 - Parks & Recreation - 31
June 2023 - Parks & Recreation - 32
June 2023 - Parks & Recreation - 33
June 2023 - Parks & Recreation - 34
June 2023 - Parks & Recreation - 35
June 2023 - Parks & Recreation - 36
June 2023 - Parks & Recreation - 37
June 2023 - Parks & Recreation - 38
June 2023 - Parks & Recreation - 39
June 2023 - Parks & Recreation - 40
June 2023 - Parks & Recreation - 41
June 2023 - Parks & Recreation - 42
June 2023 - Parks & Recreation - 43
June 2023 - Parks & Recreation - 44
June 2023 - Parks & Recreation - 45
June 2023 - Parks & Recreation - 46
June 2023 - Parks & Recreation - 47
June 2023 - Parks & Recreation - 48
June 2023 - Parks & Recreation - 49
June 2023 - Parks & Recreation - 50
June 2023 - Parks & Recreation - 51
June 2023 - Parks & Recreation - 52
June 2023 - Parks & Recreation - 53
June 2023 - Parks & Recreation - 54
June 2023 - Parks & Recreation - 55
June 2023 - Parks & Recreation - 56
June 2023 - Parks & Recreation - Cover3
June 2023 - Parks & Recreation - Cover4
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/june-2023
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/may-2023
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/april-2023
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/march-2023
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/february-2023
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/january-2023
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/december-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/november-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/october-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/september-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/august-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/july-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/june-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/may-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/april-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/march-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/february-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/january-2022
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/december-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/november-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/october-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/september-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/august-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/july-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/june-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/may-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/april-2021
https://ezine.nrpa.org/nrpa/ParksRecreationMagazine/march-2021
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