Some of these courts, by concluding that the ordinance was inapplicable to the activities of the Witnesses because those activities were not commercial, avoided questions relating to the constitutional validity of such ordinances

Relator is an ordained minister of a religious sect known as "Jehovah's witnesses" and is a member of an organization called the "Watch Tower Bible and Tract Society".

—of Louisiana held that an ordained member of the Jehovah's Witnesses, going door-to-door as an itinerant preacher and in connection therewith distributing religious literature and attempting to obtain a contribution therefor, was neither a solicitor, peddler, hawker, itinerant merchant or transient vendor of merchandise.

A contrary view to the instant case holds that an ordained minister selling religious literature does not come within the purview of licensing ordinances.

—minister's distribution of religious publications and request for contributions is not solicitation of orders

The fact that these colporteurs also sell literature which conforms to their religious beliefs does not change the nature of their profession.

To say that this transforms an activity from a religious one to a commercial one would require a similar holding as to priests and ministers of all religious denominations who accompany their visitations with the sale of Biblical literature, a position this Court will not adopt.

[BOOK] The law of fundraising

[CITATION] Charity under siege: Government regulation of fund-raising