It is not necessary that the ordinance discriminate against political speech directly or obviously in order for a court to find that the ordinance is content-based. According to Professor Tribe, regulation of certain activities “implicates the first amendment regardless of whether such regulation is cast in terms of message, or motivated by message.” Laurence H. Tribe, American Constitutional Law § 12-7, at 829. Regulation of signs is one of these activities. Id. A number of recent cases have made clear that whether an ordinance directly or indirectly prohibits political speech, it is unconstitutional if it provides more protection for commercial speech than for political speech. See Metromedia, Inc. v. City of San Diego, 453 U.S. 490, 513, 101 S.Ct. 2882, 2895, 69 L.Ed.2d 800 (1981) (<HOLDING>); Gilleo v. City of Ladue, 774 F.Supp. 1559,
holding not only does cincinnatis categorical ban on commercial newsracks place too much importance on the distinction between commercial and noncommercial speech but in this case the distinction bears no relationship whatsoever to the particular interests that the city has asserted holding that restriction on government employee speech was unconstitutionally vague holding that first amendment protections apply to compelled speech as well as restrictions on speech recognizing that noncommercial speech is accorded greater protection under the first amendment than is commercial speech and striking down ordinance that imposed a greater restriction on political than on commercial billboards recognizing that code is speech