It is one of those very Southern California disputes: a man leading free yoga by the ocean, a city insisting he needs a permit, and a federal court asked to decide whether teaching a downward dog is a form of speech.
The classes
For years, Steve Hubbard — "NamaSteve" to his students — has taught free yoga in San Diego's shoreline parks and on its beaches, passing a hat for donations rather than charging a fee. His pitch is simple: anyone should be able to practice, regardless of what they can pay.
The city's case
San Diego sees an unpermitted business. Under a city ordinance updated in 2024, teaching yoga and other fitness classes as a "service" in parks and beaches requires prior city approval — even when the classes are free or donation-based, Courthouse News reported. The city argues its rules apply evenly to everyone using public land, a matter of permits, order and access rather than of what is being taught.
The court steps in
Hubbard and a fellow instructor challenged the rules, and in June 2025 the U.S. Court of Appeals for the Ninth Circuit sided with them, ruling that teaching yoga is expression protected by the First Amendment, FindLaw reported. The court reasoned that yoga instruction — spoken guidance, philosophy and expressive movement — is more than a commercial transaction, and it faulted the city's ordinance for singling out particular activities. The decision reversed a lower court and let the oceanfront classes resume.
Still unresolved
The ruling was a milestone, not an ending. Hubbard has continued to press the case, filing a new lawsuit in 2026 over the citations he received, Axios San Diego reported. The city, for its part, has kept contesting whether donation-based classes really count as free expression rather than paid service, and further hearings lie ahead.
The stakes reach beyond one instructor. Cities across California regulate organized activity in public parks, and the case tests where the line falls between reasonable rules for shared space and a resident's right to gather and teach. For now, the practical outcome is that NamaSteve's classes go on — by the water, by donation — while the courts sort out whether a city can require a permit for a pose.
