WTO Ministerial Conference of 1999 protest activity saw a number of changes to how law enforcement deals with protest activities. "The , which has a 35-year history of monitoring First Amendment activity, has witnessed a notable change in police treatment of political protesters since the November 1999 World Trade Organization meeting in Seattle. At subsequent gatherings in Washington, D.C., Detroit, Philadelphia, Los Angeles, Miami, Chicago, and Portland a pattern of behavior that stifles First Amendment rights has emerged". In a subsequent lawsuit, the United States Court of Appeals for the Ninth Circuit found that "It was lawful for the city of Seattle to deem part of downtown off-limits ... But the court also said that police enforcing the rule may have gone too far by targeting only those opposed to the WTO, in violation of their First Amendment rights."