native, who had explored the "Skoki Valley" in Banff National Park in Canada in 1911 and became captivated by the name. Porter supported the name "Skokie" in the referendum when he returned to America. Supreme Court rulings Twice in its history, Skokie has been the focal point of cases before the United States Supreme Court. National Socialist Party of America v. Village of Skokie, 432 U.S. 43 (1977), involved a First Amendment issue. Solid Waste Agency of Northern Cook County (SWANCC) v. U.S. Army Corps of Engineers, 531 U.S. 159 (2001) touched upon the Commerce Clause. National Socialist Party of America v. Village of Skokie In 1977 and 1978, Illinois neo-Nazis of the National Socialist Party of America (NSPA) attempted to hold a march in Skokie, far from their headquarters on Chicago's south side. Originally, the neo-Nazis had planned a political rally in Marquette Park in Chicago. The park is located in what was then a predominantly all-white neighborhood, similar to the situation in 1966, when a crowd of 4,000 Marquette Park residents gathered to watch Martin Luther King Jr. lead a march, some waving Confederate flags or throwing bottles, bricks and rocks at the protesters; King was knocked to his knees when struck by a rock. However, the Chicago authorities thwarted the NSPA's plans. Seeking another free-speech political venue, the NSPA group chose to march on Skokie. Given the many Holocaust survivors living in Skokie, the village's government thought the Nazi march would be disruptive, and refused the NSPA permission to hold the event. The NSPA appealed that decision, and the American Civil Liberties Union interceded on their behalf, in National Socialist Party of America v. Village of Skokie. An Illinois appeals court raised the injunction issued by a Cook County Circuit Court judge, ruling that the presence of the swastika, the Nazi emblem, would constitute deliberate provocation of the people of Skokie. However, the Court also ruled that Skokie's attorneys had failed to prove that either the Nazi uniform or their printed materials, which it was alleged that the Nazis intended to distribute, would incite violence. Moreover, because Chicago subsequently lifted its Marquette Park political demonstration ban, the NSPA ultimately held its rally in Chicago. The attempted Illinois Nazi march on Skokie was dramatized in the television movie, Skokie, in 1981. It was satirized in The Blues Brothers movie in 1980. Migratory bird rule In 2001, the decision