When speech is involved, such as unruly, harassing demonstrations, these injunctions must balance the protesters' right to free speech with other important concerns such as a woman's physical and psychological well-being and safe access to lawful medical services, the public order, and property rights. The Supreme Court has upheld a 36-foot buffer zone, but the permissible dimensions of any buffer zone will depend on the enjoined conduct, geography, and whether the buffer zone limits no more of the demonstrators' speech than necessary. Specific Language threats, whether verbal or written, as on signs or posters. Particularly provocative language is generally not enjoinable, but at least one state Supreme Court has held that such language may be enjoinable in narrow circumstances, such as when small children are present. Noise Restrictions applicable in most localities, but difficult to enforce.
Bubble Zones restrict close approach to someone entering or leaving a clinic.
These are also created by injunctions, but such injunctions will be subject to the outcome of cases currently pending that challenge the constitutionality of bubble-zone statutes and injunctions. Residential Picketing injunctions that prevent picketing focused on a particular residence. Such injunctions are subject to rules similar to those concerning statutes against residential picketing. An injunction may prevent demonstrations not only in front of a targeted residence, but also in front of surrounding residences. Notes Bray was an appeal by Operation Rescue of a 4th Circuit Court of Appeals decision that had upheld a challenge to the organization's activities in blocking access to health care facilities in the Washington, DC, area.