Federal appeals court Good law

McClendon v. Long

22 F.4th 1330 (11th Cir. 2022)

A Georgia sheriff could not make registrants display “No Trick-or-Treat” signs in their yards. That is compelled speech.

Court
U.S. Court of Appeals, Eleventh Circuit
Decided
January 19, 2022
Reach
Binding in federal courts in AL, FL, GA
Verified
September 30, 2026
Read the opinion All cases

Good law. Still followed. Later cases may have narrowed it — see Scope. Binds federal courts in its circuit only. Persuasive, not binding, everywhere else.

What happened

In October 2018, Butts County, Georgia deputies placed signs reading “STOP / NO TRICK-OR-TREAT AT THIS ADDRESS” in the yards of all 57 registrants in the county. Three registrants sued before Halloween 2019.

What the court decided

The Eleventh Circuit held the signs were government speech and that forcing homeowners to display them is compelled speech violating the First Amendment, with no evidence that registrants posed a danger to trick-or-treaters. The court reversed in part, directing a permanent injunction for the homeowner, and vacated and remanded for the two plaintiffs who lived on their parents’ property to determine their property interest.

Why it matters to the Registry

It was the first federal appeals ruling against Halloween signs and a model for the later challenge to Missouri’s sign statute in Sanderson v. Hanaway.

What it did not decide

It concerned a sheriff’s policy, not a state statute. It did not decide whether signs placed on public rights-of-way are allowed or whether other Halloween restrictions, such as staying home or leaving lights off, are valid.

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