The U.S. Court of Appeals for the Eighth Circuit recently upheld the grant of summary judgment to an Iowa city and several police officers in their individual capacity in a Section 1983 suit brought by a street preacher who was removed from a festival area but allowed to continue his preaching across the street from the festival's entrance. The appeal resulted in an opinion from Judge Michael J. Melloy, a concurrence by Judge Lavenski R. Smith, and a dissent by Judge Ralph R. Erickson.