On March 15, the U.S. Postal Service filed this brief with the U.S. Supreme Court in Initiative & Referendum Institute v U.S. Postal Service, explaining why the U.S. Supreme Court should not hear the case. The issue whether it is constitutional to ban individuals from signing a petition on interior postal sidewalks. The Postal Service permits circulators to stand on postal sidewalks and ask people to sign, but if the individual wants to sign, the individual and the circulator must then leave postal sidewalks.
The Postal Service argument is almost entirely on the point that there is no split in the various circuits on whether post office interior sidewalks are public fora or not. The brief would have been more interesting if it talked about the issue itself. An average person would conclude that the post office’s policy does not make sense, and there is little in this brief to rebut that, except the argument that the sidewalk would be congested if signing occurred on the sidewalk.