City of Austin, Texas v. Reagan National Advertising

The Supreme Court applied the Reed test by distinguishing between the subject matter of a regulation and the task of applying it, although officials may need to read a sign's content to determine which business it advertises and thus whether the sign qualifies as on-premises or off-premises, this evidentiary requirement does not make the distinction itself content-based, because the rule turns on location and function, not the message conveyed. The Court rejected the Fifth Circuit's logic that any regulation requiring content-reading becomes per se content-based under Reed, holding instead that a neutral location-based rule remains content-neutral even if applying it incidentally requires examining the sign's message. Austin's ordinance thus survived Reed's threshold because the on/off-premises distinction is categorically different from regulations that target specific subject matter or viewpoints, it is simply a functional rule about where a business advertises relative to its premises.