Modernizing the Law of Open-Air Speech: The Hughes Court and the Birth of Content-Neutral Balancing

Threats and Responses: Overview; From New York to Melbourne, Cries for Peace, N.Y.TIMES, Feb. 16, 2003, § 1, at I (noting that "[c]rowd estimates are often little more than politically tinged guesses"; police estimated the crowd to be 100,000, while organizers said 400,000 people attended), available at LEXIS, News Library, NY Times file.In Washington, D.C., a frequent site of large protests, "the United States Park Police stopped providing counts for rallies after bitter disputes over past estimates."Robin Toner, Abortion Rights Marchers Vow to Fight Another Bush Term, N.Y.