In Krishna Lunch of Southern California, Inc. v. Gordon, (CD CA, Feb. 9, 2018), a California federal district court dismissed a challenge by a Krishna consciousness organization to a UCLA rule that limits it to holding four event per year on the campus.  The organization, Krishna Lunch, wants to offer a lunch program with sanctified food (prasada) 2 or 3 times per week.  The court rejected free exercise, free speech and expressive association challenges to the limitation.  In rejecting plaintiff’s expressive conduct claim, the court said in part:Plaintiffs’ lunch program … is afforded First Amendment protection only if there is an intent to convey a particularized message and a great likelihood that message would be understood by those who view it….The Court previously concluded that Plaintiffs failed to allege a great likelihood their pro-animal/antimeat message would easily be understood by those who view it.  They still have not done so……. [T]he fact that the Assigned Area (the location where Plaintiffs would conduct prasada) is regularly used by groups for which food distribution is common … makes it highly unlikely that the ordinary viewer would glean a particularized message from Plaintiffs’ lunch program.



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