The second landmark decision by the Supreme Court was Reed v. Town of Gilbert (2015). In Reed, the Court reviewed the constitutionality of a sign ordinance in Gilbert, Arizona, which regulated the manner signs could be displayed in public areas. The ordinance banned the display of outdoor signs without a permit. However, the ordinance included over twenty categorical exemptions. For instance, "ideological" signs could be placed in the zoning district for an indeterminate amount of time and "political" signs were allowed in the district for up to 60 days before a primary election and up to 15 days following a general election. However, “temporary directional signs relating to a qualifying event", which directed "pedestrians, motorists, and other passersby" to events hosted by non-profit organizations, could only be displayed in the district twelve hours before the start of the event and had to be taken down an hour after the event. The size of the signs were also regulated depending on the category. The Court held that the signs were a content based regulation because it distinguished signs based on their topic. Under First Amendment jurisprudence, content based regulations receive strict scrutiny. The ordinance was struck down.