avoidance of what may be perceived to be offensive behavior (see Johnson & Cnaan, 1995).
The criminalization of begging is hardly a recent phenomenon (Guest, 1989; Trattner, 1994). English Poor Laws were enacted to curb groups of homeless people from roaming from one community to another and menacing the general population (see Papachristou v. City of Jacksonville, 405 U.S. 156, n. 4 ). It is the range of begging approaches that is difficult to categorize. These include verbal or nonverbal; unobtrusive or aggressive; polite or intimidating; nonphysical to quasi-assaultive. A beggar has a right to communicate in any manner in which he or she chooses, so long as it is not unduly intrusive. Many lawsuits regarding the finer points of this issue have been filed (e.g., Young v. New York City Transit Authority, 903 F.2d 146, cert, denied, 498 U.S. 984 ), but the Supreme Court has yet to hear a case that specifically delineates the impact of the First Amendment on the right to beg as distinguished from the right to solicit for other charitable purposes.