The 1999 World Trade Organization (WTO) ministerial meeting in Seattle was
the target of highly organized, widely supported protest demonstrations. In
response to the protests. city officials declared a state of emergency, or
dering nighttime curfews and a daytime "no-protest zone" in downtown Seattl
e. They reasoned that the zone was necessary to protect the rights of WTO d
elegates and to restore public order. This Comment argues that mass nonviol
ent protests deserve more First Amendment protection than was afforded to d
emonstrators in Seattle. Even when violence occurs and public order is thre
atened, governments must narrowly tailor emergency orders to avoid tramplin
g on peaceful protesters' First Amendment rights. An analysis of U.S. Supre
me Court and Ninth Circuit case law demonstrates that Seattle's "no-protest
zone" was unconstitutional and that courts should strike down similar rest
rictions on mass protests.