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CLAYTON, Mo. – A homeless man is suing St. Louis County, claiming the more than three dozen tickets he has received for begging for money at a busy intersection violate his constitutional right to free speech.

KMOX Radio reports that Robert Fernandez frequently stands at the intersection of Lindbergh Boulevard and Interstate 55 with a sign asking for money. His federal lawsuit was filed earlier this summer and seeks a preliminary injunction preventing St. Louis County from enforcing its law against soliciting.

Fernandez, who is in his mid-40s, has been ticketed 38 times.

A response from the county is due by Tuesday. The county counselor’s office declined comment, citing pending litigation.

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Information from: KMOX-AM, http://www.kmox.com