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A City of Griffin ordinance prohibited the distribution of circulars, handbooks, advertising, or literature of any kind within the city limits without first obtaining written permission from the City Manager. Lovell (D) distributed a religious pamphlet and magazine without obtaining written permission. D did not apply for a permit and admitted to her violation of the ordinance. D was convicted and was sent to prison for 50 days after defaulting on a $50 fine. D appealed, claiming that the ordinance violated freedom of the press and religion.

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