Open your doors to the public, your property becomes a "public place" if the ACLU had its way. When the rainbow protestors show up at your church to speak out against the church teaching against homosexuality, how do you get them to stop their disruption, as they are now making their protest in "a public place"?
There was an injunction against congregating on the steps of the church, so when the police arrived, they would clear off everybody, including church people coming out of Mass, who were then obliged to go through the jeering homosexual throng, which was humiliating as well as dangerous. The NYC police called this "even-handed enforcement."
I think it's a matter of sheer political power. If the Mayor and the Chief of Police were determined to shield the churchgoers from noisy confrontation, they could have curbed ACT-UP; but since they were sympathetic to, or at least intimidated by, ACT-UP and its supporters, the cops allowed innocent church-goers to be obscenely harrassed on a regular basis.
If I am not mistaken, the private property of a church, residence, or business includes the sidewalk to the curb. Technically. Does anybody know?