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In 2021, the City of Laguna Beach, California, adopted a policy banning street performances on the Forest Avenue Promenade — a pedestrian mall in the city’s downtown — outside of a small “performance deck,” which is accessible only to performers who obtain a permit. In April 2023, a police officer enforced the policy against professional musician and street performer Mike Bolger while he was busking on the promenade. A city official later told Bolger the city schedules permitted performances on the performance deck three nights per week, and it was booked for at least the next 6 months.

On August 14, ����ֱ�� wrote the Laguna Beach City Council, explaining that the promenade policy’s broad restrictions on street performances violate the First Amendment. The city responded on August 18, noting that a new city attorney would review ����ֱ��’s letter after coming on board on September 11. After receiving no further response, ����ֱ�� sent a follow-up letter to the city on October 10.