968 F.2d 991 (9th Cir. 1992) Cited 19 times
In Sparks Nugget, the Ninth Circuit went further by finding that the inaccessibility exception does not apply at all in situations where customers, and not employees, are the target audience; alternatively, the court stated that, even if the exception were applicable, Lechmere would require a finding that the intended audience is presumptively not inaccessible "because the targets of the union protest do not reside on the employer's property."