Paulsen v. Lehman
Mitch Paulsen, director of Mitch Paulsen Outreaches, sought a preliminary injunction against the New York State Office of Parks, Recreation and Historic Preservation (SOP) after his request to distribute religious pamphlets at Jones Beach State Park on September 1, 1990 (Labor Day weekend) was denied. SOP cited a policy of not issuing permits on holiday weekends due to staffing shortages and strained resources. The Court, presided over by District Judge Spatt, found that SOP failed to establish a legitimate governmental interest for a total ban on leaflet distribution and that the alternative channels of communication offered were inadequate. Consequently, the Court granted Paulsen's application for a preliminary injunction, ordering SOP to issue a permit allowing him and two associates to distribute literature in the mosaic area of Jones Beach on September 1, 1990, from 11:00 a.m. to 2:00 p.m., with a condition for cleanup. The ruling was limited to this specific request, without determining the constitutionality of the overall holiday weekend policy.