In Daley v. City of Sarasota, Florida’s Second District Court of Appeal struck down a municipality’s attempt to impose an absolute ban on amplified noise emanating from unenclosed structures within certain zoning districts during specified hours of the day and night. The appellate court found that, despite the City’s laudable goal in attempting to regulate unreasonable noise, the First Amendment prohibits local governments from completely banning amplified noise. The Second District Court of Appeal’s holding extends to amplified commercial noise as well. Hence, any attempt to regulate amplified noise is “subject to strict guidelines and definite standards closely related to permissible governmental interests” and “must be sufficiently definitive as to secure against arbitrary enforcement.”