United States v. O'Brien, 391 U.S. 367 is the relevant precedent. > When "speech" and "nonspeech" elements are combined in the same course of conduct, a suffic

United States v. O'Brien, 391 U.S. 367 is the relevant precedent. > When "speech" and "nonspeech" elements are combined in the same course of conduct, a sufficiently important governmental interest in regulating the nonspeech element can justify incidental limitations on First Amendment freedom So long as Gilbert has an "substantial" interest in preventing derelict cars and the regulation doesn't go beyond what's necessary, it would stand.