This page hosts court records from Sara Duvall v. City of San Diego, a federal lawsuit filed in the U.S. District Court for the Southern District of California challenging the city’s enforcement of its sidewalk-vending and expressive-activity ordinances.

San Diego artist Sara Duvall alleged city park rangers cited and fined her twice for displaying and selling her artwork in Balboa Park after determining that her sculptures were “handcrafts” rather than protected artistic expression.

The complaint alleges that Duvall has long shown and sold her mixed-media sculptures in Balboa Park, a traditional public forum, but that park rangers began citing her after 2024 revisions to the city’s municipal code governing expressive activity and sidewalk vending.

Read the story: San Diego artist sues city for claiming she is not an artist


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