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Reed V. Town of Gilbert


In June 2015, the U.S. Supreme Court handed down its first decision specifically focusing on sign regulations in more than 20 years.


Reed v. Town of Gilbert (Ariz.) stemmed from a church’s use of temporary directional signs. Since the services were held in different venues each week, these signs let people know the location of the meeting. The town’s sign code limited how long these kinds of signs could be displayed and their size. Other types of temporary signs – including those with political and ideological messages – could be much larger and displayed far longer.

The court unanimously found that placing limits on temporary directional signs that were more stringent than these other types of temporary signs was a content-based regulation of speech—a violation of the First Amendment.

While the court’s ruling was unanimous, some justices differed with the majority’s written opinion and offered their own concurring opinions.

To help communities create reasonable sign regulations, ISA offers:

  1. Free sign code assistance to you and your community: Contact David Hickey as you hear of sign ordinance issues
  2. Vital Signs: Free educational resources for planners and local government officials


In the aftermath of Reed, ISA has educated thousands of planners and other local officials about the case and ways that a community can ensure that its sign regulations are content-neutral. This includes sessions at the APA National Planning Conference in 2016, 2017 and 2019, sessions at thirteen state or regional APA chapter events, two webinars and resources from the Sign Research Foundation (SRF).

These resources include:


The Supreme Court ruling in Reed v. Gilbert intensified our efforts to positively influence sign codes throughout the United States, using SRF resources to provide education for planners, city attorneys and other local officials.

However, soon after the Reed decision it became apparent that the Outdoor industry was going to litigate the question of whether the traditional regulatory distinction between on-premise and off-premise signs (billboards) was content-based. The first major decision on this issue was Lamar v. City of Los Angeles, in which ISA joined with the California Sign Association (CSA) to defend the ability of Los Angeles to treat on-premise signs differently than billboards. 

Other cases on this issue subsequently wound their way through the federal court system, including Thomas v. Schroer in the U.S. Sixth Circuit Court of Appeals and Austin v. Reagan in the U.S. Fifth Circuit Court of Appeals.