[1][2] In 1943, a woman from Struthers, Ohio by the name of Thelma Martin went knocking on doors to pass out Jehovah's Witness leaflets to people in her city.

[4] She was convicted "in the Mayor's Court" and fined $10.00[5] (equivalent to $180 in 2023) for violating a Struthers, Ohio city ordinance which made it illegal to knock on doors to distribute handouts to that contained information about religious meetings.

It submits the distributor to criminal punishment for annoying the person on whom he calls, even though the recipient of the literature distributed is, in fact, glad to receive it.

Justice Reed wrote: The most ... that can be or has been read into the ordinance is a prohibition of free distribution of printed matter by summoning inmates to their doors.

There are excellent reasons to support a determination of the city council that such distributors may not disturb householders while permitting salesmen and others to call them to the door.