Consequently, we believe that the posting of political signs on Oahu two months before an election is not validly prohibited. No similar temporal limitation exists for commercial or for other noncommercial signs. Although the U.S. Supreme Court has not yet decided whether laws which impose durational limitations on political signs but not on other signs violate the First Amendment, it held an ordinance unconstitutional which purported to completely prohibit political yard signs. In this case, we are not persuaded that adequate substitutes exist for the important medium of speech that Ladue has closed off.
Residential signs are an unusually cheap and convenient form of communication.
Especially for persons of modest means or limited mobility, a yard or window sign may have no practical substitute. . . . Furthermore, a person who puts up a sign at her residence often intends to reach neighbors, an audience that could not be reached nearly as well by other means. Given the Court's strong language about the primacy of political signs, it may not readily find adequate alternative channels for such communication whether in the context of laws which prohibit or which regulate such signs. A law that contains a content-based restriction is presumptively unconstitutional. City of Renton v.