Princeton University v. Schmid
Headline: Court dismisses appeal over campus leafleting rules, refusing to decide the constitutional challenge after Princeton changed its rules and the case became moot, leaving a state-court reversal in place.
Holding: The Court dismissed the appeal for lack of a live controversy and jurisdiction because Princeton amended its campus rules while the case was pending, rendering the federal constitutional question moot and blocking review.
- Supreme Court declines to resolve the constitutional challenge now.
- Princeton changed rules to avoid immediate federal review of campus leafleting.
- Schmid's conviction stays reversed under the New Jersey Supreme Court ruling.
Summary
Background
A private citizen, Schmid, was arrested for distributing political materials on Princeton University's campus without the required permission. He was not a student. A municipal court convicted him and fined him $15 plus $10 costs. A de novo trial in the state superior court again convicted him and imposed the same fine. The New Jersey Supreme Court reviewed the case, invited the University to intervene, and reversed the conviction on the basis that Schmid’s speech and assembly rights under the New Jersey Constitution had been violated.
Reasoning
Princeton asked the United States Supreme Court to review the state-court reversal, claiming the decision violated the University’s rights under the First, Fifth, and Fourteenth Amendments. The State of New Jersey joined the appeal but declined to take a position on the merits. While the case was pending, the University substantially amended the campus rules governing solicitation and literature distribution by nonmembers. The Supreme Court concluded the old regulation was no longer in force, the lower court had not ruled on the new rule, and the dispute had lost its character as a live controversy. Because the Court does not issue advisory opinions on abstract questions, it found no jurisdiction and dismissed the appeal.
Real world impact
The decision leaves the New Jersey Supreme Court’s reversal in place and prevents immediate federal review of Princeton’s revised rules. The University may still seek to test the new regulation in a future enforcement case. Justice Brennan took no part in this decision.
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