In New Times, Inc. v. Arizona Board of Regents, 110 Ariz. 367, 519 P.2d 169 (1974), the Arizona Supreme Court held unconstitutional a university regulation that limited the number of newsstands for distributing off-campus newspapers and imposed a fee for each newsstand. The only reason the university advanced for the regulation was "to limit the amount of litter resulting from the disposal of newspapers and to cover the additional cleanup costs involved." New Times, 110 Ariz. at 372, 519 P.2d at 174. The Court stated that "the problem of litter control is not of sufficient importance to balance the risk of abridging First Amendment freedoms. . . . The university clearly has the power to regulate the conduct of those who actually cause the litter rather than the publishers of such newspapers." New Times, 110 Ariz. at 372, 519 P.2d at 174.