In Village of Schaumburg v. Citizens for a Better Environment, 444 U.S. 620, 632, 100 S. Ct. 826, 63 L. Ed. 2d 73 (1980), the Court considered a municipal ordinance that required organizations soliciting contributions door-to-door to have a permit. Schaumburg, 444 U.S. at 622-23. In order to obtain a permit, an organization had to prove that at least 75% of the proceeds of the door-to-door solicitations would be directly used for the organization's charitable purpose. Id. at 624. The Village of Schaumburg (Village) advanced as substantial governmental interests backing its regulation the interests of "protecting the public from fraud, crime and undue annoyance." Id. at 636. The Federal Court held that the regulation was not narrowly tailored because it inaccurately presumed that any organization "using more than 25 percent of its receipts on fundraising, salaries, and overhead is not a charitable, but a commercial, for-profit enterprise and that to permit it to represent itself as a charity is fraudulent." Id. The Court found this presumption to be overbroad, because advocacy, research, and public education can often be tied into charitable solicitation. Id. The Court held that the Village could more effectively further its substantial interest in combating fraud through means that would not infringe on charities' free speech rights, such as direct penal prohibitions on fraudulent conduct or financial reporting requirements. Id. at 637-38.