2014—In Bible Believers v. Wayne County, a divided panel of the Sixth Circuit confers “a clear heckler’s veto,” as dissenting judge Eric L. Clay puts it—or is it a thug’s veto?—on an angry crowd at the 2012 Arab International Festival. The panel majority rules that the “threat of violence” at the festival on the streets of Dearborn, Michigan “had grown too great to permit [a group of Christian evangelists] to continue proselytizing.”
Three months later, the Sixth Circuit will grant en banc review of the ruling. In October 2015, the en banc Sixth Circuit, in a majority opinion by Judge Clay, will hold that county police violated the constitutional rights of the Christian evangelists when they barred them from continuing to proselytize.