Wanting to educate the public about the fine details of the federal healthcare law, attorney David Kolhoff contacted the Allen County Public Library about setting up his laptop on a mobile cart in a large open plaza abutting the library.

When the library denied him use of the space, he enlisted the ACLU of Indiana to file suit on his behalf. The library did not contest the fact that, if its plaza area is considered a traditional public forum, the prohibition of Kolhoff's expressive activity would be in violation of the First Amendment to the U.S. Constitution. We argued that the speech was not disruptive and that the First Amendment protects Kolhoff's rights to engage in this expression at library. We refuted the Library's contention that the plaza was a "limited public forum," argued its status as a library was a significant issue, and concluded that the prohibition on Kolhoff's expressive activity was unconstitutional even if the plaza is a limited or non-public forum.

The right to exercise First Amendment free expression in public gathering spaces cannot be denied without a legitimate reason.

In October 2012, the lawsuit, David J. Kolhoff v. Allen County Public Library, was settled with an agreement that allowed Kolhoff to set up his display about the healthcare law on the plaza but away from the building's caf_ area.