HomeMy WebLinkAboutMISC LOCAL REGULATION OF
SEXUALLY ORIENTED BUSINESSES
WILLIAM M. McKAMIE
FLETCHER & SPRINGER, LLP
13750 San Pedro, Suite 600
San Antonio, Texas 78232
(210) 546 -2122 (Telephone)
(210) 546 -2130 (Telecopier)
mick @fletchspring.com
Presented to the Texas City Attorneys Association
Semi - Annual Summer Meeting
South Padre Island, Texas
June 7, 2002
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LOCAL REGULATION OF SEXUALLY ORIENTED BUSINESSES
I. Introduction
* What is a Sexually Oriented Business? - Adult businesses in America continually change
their nature and character. There is a plethora of sexually explicit materials available to the public
in a variety of different venues and in a variety of different types of businesses. So what type of
establishment constitutes a sexually oriented business?
The Supreme Court has upheld definitions that properly balanced First Amendment interests
with the needs of local governments to regulate time, place and manner of businesses commonly
associated with harmful secondary effects. While a regulation must not require people of normal
intelligence to guess at its meaning, Grayned v. City of Rockford, 408 U.S. 104, 108 (1972), the
prohibition against successive vagueness "does not invalidate every statute which a reviewing court
believes could have been drafted with greater precision." Rose v. Locke, 423 U.S. 87, 94 (1975).
For example, in Young v. American Mini - Theatres, the City of Detroit defined an "adult
motion picture theater" as:
An enclosed building with a capacity of fifty or more persons used
for presenting material distinguished or characterized by their
emphasis on matter depicting, describing or relating to "specified
sexual activities" or "specified anatomical areas," (as defined below),
for observation by patrons therein. Young, 427 U.S. 50, at 53, n. 5.
The plaintiff challenged this definition as vague, claiming that adult motion picture theatre operators
would have to guess at when a film would cross the threshold amount of sexual activity to require
the theatre showing it to be licensed. The Supreme Court held that the plaintiff adult businesses fell
clearly within the definition, because they regularly offered adult films.
In City of Erie v. Pap's A.M., 529 U.S. 277, 289 (2000):
"Nudity" means the showing of the human male or female genital,
pubic area or buttocks with less than a fully opaque covering; the
showing of the female breasts with less than a fully opaque covering
of any part of the nipple; the exposure of any device, costume, or
covering which gives the appearance of or simulates the genitals,
pubic hair, natal cleft, perineum anal region or pubic hair region; or
the exposure of any device worn as a cover over the nipples and/or
areola of the female breasts, which device simulates and gives the
realistic appearance of nipples and/or areola."
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This definition has been upheld as sufficiently clear to support regulation, and is used widely in
licensing and zoning ordinances. Of course, it can be presumed that a venue that features nudity as
defined above, is a sexually oriented business. Typically, ordinances contain definitions of sexually
oriented businesses to include gentlemen's clubs, cabarets, some massage parlors, escort services,
nude modeling studios, adult video stores, peep show parlors, nude dancing establishments, and like
businesses.
* Why Regulate SOB's? - Sexually oriented businesses have expanded and grown
significantly in the last decade. In 1996, the portion of the entertainment industry that focuses on
adult and sexually oriented entertainment grossed approximately $8,000,000.00. Alan C. Weinstein,
"Licensing Ordinances as an Adjunct to Zoning Regulation of Sexually Oriented Businesses (Part
I), "22 ZONING AND PLAN. L. REP. 2 (1999). As these businesses have expanded, cities have adopted
ordinances to impose location restrictions and operational standards that prohibit a physical contact
between performers and customers, prohibit direct tipping of performers, and impose distance
restrictions between performers and customers. The owners and operators of sexually oriented
businesses have been aggressive in challenging many of these regulations, resulting in a fairly rapid
change in constitutional applications and a critical analysis of state and local laws.
A variety of substantial governmental interests are advanced by the licensing and regulation
of sexually oriented enterprises. Communities seeking to avoid criminal activity in an adult
business, have an interest in ensuring that the persons operating the establishment have not recently
been convicted of crimes. Requiring licenses of owners and employees of the business serves to
identify participants in the enterprise, and helps to prevent employment of minors. Interior
configuration standards and prohibitions on certain conduct, prevent illicit sexual activity and
protect the public health from problems associated with peepshow booths and nude dancing
establishments. The Supreme Court has recognized that a city has broad police power to prevent
the negative secondary effects of sexually oriented businesses through special regulations.
A number of cases have found that prostitution, indecent exposure, masturbation and :other
elicit sexual activity frequently occur on the premises (and in the vicinity) of sexually oriented
businesses. Nobby Lobby, Inc. v. City of Dallas, 970 F.2d 82 (5 Cir. 1992). Courts have upheld
regulations that require booths to either be visible by persons adjacent to the booth, or by an
employee who is required to monitor booth activity, in spite of privacy and equal protection
challenges. These regulations combat prostitution. Bamon Corp. v. City of Dayton, 923 F.2d 470
(6 Ciri 1991).
* Types of Local Regulation - Regulation of sexually oriented businesses has evolved into
the following general categories: zoning (location regulations), licensing (qualification standards),
and operational (protective safeguards).
While completely nude dancing in adult entertainment establishments can be prohibited,
complete nudity may not be prohibited in other entertainment venues such as performances in
theatres. Therefore, a prohibition against "any person appearing in a state of nudity in any place
where the general public is invited," is void on its face for overbreadth. An operator of an adult
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entertainment establishment could successfully challenge a prohibition on completely nude dancing,
notwithstanding that prohibition of completely nude dancing and adult entertainment establishments
could be constitutionally prohibited. Note that most updated city sexually oriented business
regulations require performers to wear pasties and a G- string. City of Erie v. Pap's A.M., 529 U.S.
277 (2000). In Pap's A.M., the Supreme Court held that an ordinance prohibiting public nudity did
not infringe unnecessarily on the constitutional rights of nude dancers in nude dancing
establishments, by requiring them to wear pasties and G- strings during their performances. Justice
Rehnquist stated that requiring the dancers to wear pasties and a G- string "does not deprive the
dance of whatever erotic message it conveys."
B. General Constitutional Principles
As a constitutional matter, the value of freedom of expression prevails over other democratic
values. In litigation, this principle serves as the basis for challenging the constitutionality of law or
governmental action on First Amendment grounds. The defense against such a challenge can often
be difficult to make. The general rule of law that statutes are presumed to be constitutional does not
apply in the case of regulations affecting free speech rights, including those involving sexually
oriented expression. The burden of proving the constitutionality of regulations shifts to the
government. It is especially important that a record be developed prior to the adoption of the
ordinance or regulation, even if the record is composed only of studies conducted in similar
jurisdictions.
Regulations that are directed to a particular view point or content of speech are subject to
strict scrutiny, and a compelling interest must be demonstrated by a government to support such
regulations. Most land use regulations oriented toward the land use perimeters of time, manner and
place, rather than toward particular view point or content, but where time, place and manner
restrictions are involved, the First Amendment requires that regulations must be "no greater than
necessary" to protect the substantial governmental interest sought to be advanced. Federal court
decisions on whether there is an adequate fit between the purpose and the means of the regulations
are generally case specific, so each community and its regulations must be carefully crafted. The
local government attorney must closely examine court opinions and look for principles and results
that may apply to a particular regulation.
* -'The Narrow Specificity Principle — This principle forms a part of a commercial speech
doctrine and stands for the proposition that a regulation must be no more extensive than necessary
to advance the legitimate governmental interest at stake and must allow ample opportunity for an
expressive message to be conveyed.
* The Content Neutrality Principle — The government may not proscribe any expression
because of its content, and an otherwise valid regulation violates the First Amendment if it
discriminates among different types of expression based upon content. Under the view point
neutrality aspect of the principle, the government cannot regulate expression in such a way as to
favor one view point over another. Under the category neutrality aspect of the principle, the
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government generally cannot regulate in such a way as to discriminate between different categories
of expression. There are two exceptions to the principle of category neutrality, both of which are
applicable to land use regulation by local governments. First, in order to deal with undesirable
secondary effects resulting from concentration of adult entertainment establishments in a particular
area, the government can enact zoning regulations specifically applicable to those establishments
(such as a requirement that dancers wear a small amount of clothing in order to deal with the
undesirable secondary effects associated with nude dancing).
The Supreme Court has dealt with governmental licensing of expression by imposing very
specific requirements on such licensing.
* The Prior Restraint Doctrine — A prior restraint directly interferes with the ability of the
public to receive information, and has a freezing effect on expression. Therefore, a prior restraint
is presumptively unconstitutional and imposes on the government a heavy burden of justification.
In Freedman v. Maryland, 380 U.S 51 (1965), the Supreme Court held that "any system of prior
restraint" bears a "heavy presumption against its Constitutional validity." For our prior restraint
to be upheld, the following safeguards must be met:
1. The decision to issue or deny a license must be made within a brief, specified and
reasonably prompt period of time;
B. The licensing scheme must provide for prompt judicial reviews; and
C. The burden of initiating review must be on the government, not on the challenger.
* The Commercial Speech Doctrine — The constitutionality of governmental regulation of
commercial speech requires application of this four -part analysis:
I. The commercial speech must concern lawful activity and must not be misleading.
II. The government must have a substantial interest to justify the regulation.
III. The regulation must directly advance the asserted governmental interest.
IV. The regulation may not be more extensive than is necessary to serve the asserted
interest.
The government will not be given the benefit of the doubt about the constitutionality of a land use
regulation, and the burden of sustaining the regulation against a constitutional challenge falls on the
local government. The regulation must be carefully tailored to achieve its legitimate, stated public
purpose. Land use permit requirements must provide for a specific and speedy decision by the
licensing body to avoid being held an invalid "prior restraint" on speech. First Amendment
protection against prior restraint on speech impose substantial restrictions on the types of land use
regulation available to local governments. Clear standards must be provided to guide the discretion
of the local official. The local official must decide on the permit within a specific and brief period,
during which the status quo must be preserved. The regulation must state and express a prompt
judicial review procedure in a case of a denial. An important effect of the prior restraint doctrine
is to discourage conditional use permits in favor of permits issued as a matter of right. A conditional
use permit necessarily requires discretion from the local government agency. It is, therefore, subject
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to criticism as being vague and over broad. Local land use regulations affecting First Amendment
issues oriented business must be carefully drafted to include specific application requirements,
review standards, and review procedures.
Courts increasingly invalidate sexually oriented business regulations, because administrative
and judicial review is not sufficiently prompt. Since 1998, this has been one of the most frequent
challenges to local ordinances. Baby Tam and Co., Inc. v. City of Las Vegas, 154 F.3d 1097 (9 Cir.
1998) (Baby Tam I); Baby Tam and Co., Inc. v. City of Las Vegas, 199 F.3d 111 (9` Cir. 1999)
(Baby Tam II); Baby Tam and Co., Inc. v. City of Las Vegas, 247 F.3d 1003 (9 Cir. 2001) (Baby
Tam III). Cases now often involve the constitutional standard for determining whether a sexually
oriented business regulation leaves reasonable alternative locations to lawfully operate. City of
Renton v. Playtime Theatres Inc., 475 U.S. 41 (1986).
* Sexually Oriented Business in a Small Community — Case law has established that
non - obscene adult entertainment is a protected First Amendment activity, for which local
governments must make sites reasonably available. Arguably, the Supreme Court has held open the
possibility that not every small jurisdiction must allow sexually oriented businesses. Schad v.
Borough of Mount Ephraim, 452 U.S. 61 (1981). For example, in Boss Capital, Inc. v. City of
Casselberry, 187 F.3d 1251, n. 2 (11 Cir. 1999), the Court determined that the relevant real estate
market contained available sites for adult entertainment, including those as far as one and a quarter
mile south of the city limits. Previously, the same court had noted that the Supreme Court had not
decided that "eve unit of local government entrusted with zoning responsibilities must provide a
commercial zone in w rich protected activities Digital Properties, Inc. v. City of
Plantation, 121 F.3d 586, n. 2 (11` Cir. 1997)
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* Is the Speech or Conduct Protected? — In order for First Amendment speech
protections to apply, there must be some type of speech or expression involved. Questions arise as
to whether nudity or nude dancing is a type of protected speech or expression. The Supreme Court
has stated that speech is not limited to the spoken or written word. City of Erie v. Pap's A.M., 529
U.S. 277 (2000). First Amendment speech protection can extend to conduct, as long as the conduct
is accompanied with some type of expression. Texas v. Johnson, 491 U.S. 397, 404 (1989). To be
considered speech, the conduct also must demonstrate a sufficient amount of expression. Conduct
signifying only a small amount of the expression will not be protected under the First Amendment.
Spence v. Washington, 418 U.S. 405 (1974). In that case, the Supreme Court held that conduct is
protected by the First Amendment when: "(1) an intent to convey a particularized message was
present; and (2) the likelihood was great that the message would be understood by those who viewed
it.
Not all adult businesses are entitled to First Amendment protection. Many sexually oriented
business ordinances encompass sexual encounter clubs, escort services, massage parlours, movie
theatres, video stores, and cabaret or dance clubs. There is a difference in the type of protection to
which such businesses are entitled. The Supreme Court unequivocally held that adult businesses
that do not "purvey sexually explicit speech," such as "escort agencies and sexual encounters
centers" are not protected by the First Amendment. FW /PBS Inc. vs. City of Dallas, 493 U.S. 215.
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In Pap's A.M., Justice O'Connor stated that "being in a state of nudity is not an inherently
expressive condition." Pap's A.M. at 289. The Court has implied that certain types of expression,
such as offensive, indecent, or expression related to child pornography, is less deserving of full
protection than more traditional types of speech. The Court has decided that this type of "lower
value" speech can be regulated more heavily than "higher value" speech. Young v. American Mini
Theatres, 427 U.S. 50 (1976). The Supreme Court, however, has never determined precisely which
adult businesses are entitled to heightened constitutional scrutiny.
* Evidence of Harmful Secondary Effects — The majority of the Supreme Court in Pap's
A.M., stated that "as long as the evidence relied upon is reasonably believed to be relevant to the
problem that the City addresses," then the City does not have to produce its own evidence, but may
rely on evidence ofharmful secondary effects, the nude dancing. Pap's A.M., 529 U.S. at 296. Even
though it is not clear how much evidence of secondary effects a government must show to justify
its need for the law, local governments now have a discussion of the sufficiency and insufficiency
of particular evidence in the majority and concurring opinions in Pap's A.M.
The 9 Circuit invalidated the City of Las Vegas' adult business ordinance as a prior
restraint. In two decisions known as the "Baby Tam" cases, the Court found that the ordinance did
not provide for prompt judicial review in the event of a license denial. Baby Tam and Co., Inc. v.
City of Las Vegas, 154 F.3d 1097 (9 Cir. 1998) (Baby Tam I); Baby Tam and Co., Inc. v. City of
Las Vegas, 199 F.3d 111 (9 Cir. 1999) (Baby Tam II).
In Reno v. ALCU, 521 U.S. 844 (1997) the Supreme Court intimated that the internet is now
the principal channel through which most Americans can receive sexually explicit communication.
The Court also identified the widespread availability of sexually explicit material through the
internet including hard core pornography. Reno, at 2336. Therefore the internet as an available
alternative venue for First Amendment expression is an argument that could be made to help support
location restrictions of sexually oriented businesses.
3. Zoning — major cases
United States v. O'Brien, 391 U.S. 367 (1968), is the landmark political speech case,
establishing the framework for evaluating content neutral regulations of conduct with an incidental
impact bn expression. A regulation is valid if it:
1. Is within the constitutional power of the government;
2. Is designed to service substantial governmental interest that is unrelated to the
suppression of free expression;
3. Is narrowly tailored to serve the interest;
4. Leaves open reasonable alternative avenues of communication. Many challenges
against zoning ordinances center around the requirement that reasonable alternative
avenues of communication be provided.
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In Young v. American Mini Theatres, Inc., 427 U.S. 50 (1976), the operators of two adult
theatres in Detroit challenged the City's ordinance that required adult theatres (defined or referring
to the content of films shown) to be licensed and to be located at least 1000 feet away from any two
other regulated uses (adult theatres, taverns, pool halls, etc.). Based upon the substantial
justifications given for the ordinance by Detroit's city council, the district court granted summary
judgment for the City. The Sixth Circuit reversed, holding that the ordinance was a content based
prior restraint on speech, and was not justified by merely establishing that it was designed to serve
a compelling public interest. The Supreme Court reversed in a 5 -4 decision, with Justice Stephens
writing the majority opinion. The Court held that the ordinance was not vague for failure to specify
exactly how much of a film must be sexual in nature before the film could be characterized by an
emphasis on sex, because the theatres regularly featured erotic films and there was no question of
the applicability of the ordinance to those activities. The Plaintiffs were held not to have standing
to assert the First Amendment rights of third parties, because they did not show that the threat of the
ordinance being applied improperly was real and substantial, and because any ambiguity could be
corrected through a narrowing construction by the state courts.
The licensing and zoning ordinances in question were determined to be valid means to
protect the quality of life and neighborhoods, and did not constitute a prior restraint on speech. In
this case the Supreme Court broadly sustained the power of local governments to utilize land use
regulations, to protect the quality of life of their citizens. The Court recognized that the
governmental interest to prevent the adverse effects of adult businesses is important and substantial,
and the government's interest in stable neighborhoods was unrelated to the suppression of any
message. The Court also held that the impact of the regulations upon erotic expression was
incidental and, no more than necessary to prove further the governments interest in protecting
neighborhoods.
City of Renton v. Playtime Theatres, 475 U.S. 41 (1986) was decided ten years after Young.
The City of Renton adult theatre zoning ordinance was analyzed as a content neutral regulation, with
the stated purpose to prevent the secondary effects of sexually oriented businesses upon
neighborhoods. The Court found that the ordinance served a substantial governmental interest , even
though the City of Renton failed to conduct a local study or to demonstrate that the impact of adult
theatres in Renton nullified the claim of substantial governmental interest. The Court explicitly
held:
The First Amendment does not require a city, before enacting such
an ordinance, to conduct new studies or produce evidence
independent of that already generated by other cities, so long as
whatever evidence the city relies upon is reasonable believed to be
relevant to the problem that the city addresses. Renton, 475 U.S. 41,
51 -52 (1986).
The City of Renton relied upon the study and experiences of Seattle, and the Court held that was
sufficient, despite the fact that the zoning regulations that Seattle used were different from those
used in Renton. Importantly, the court also addressed the issue of whether the zoning regulations
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allowed for "reasonable alternatives of communication." The court held that Renton's ordinance
met the standard because more than 5% of the land mass in Renton was opened to adult theatres.
The plaintiffs had claimed that practically none of the land was for sale or lease, so that none of the
available space was commercially viable. The Court held that these factual circumstances, even if
true, would not demonstrate a defect in the city's regulation, finding that the adult theatres "must
fend for themselves in the real estate market on an equal footing with other prospective purchasers
and lessees." Renton, 475 U.S. at 54.
Improper interpretation of ordinance terms by regulatory officials can also lead to
invalidation of the regulations. In Tollis v. San Bernardino County, 827 F.2d 1329 (9 Cir. 1987),
a county official interpreted the county's adult use ordinance to apply to mainstream theaters, even
if the theater showed pornographic films only on one occasion. The district court agreed with the
Plaintiff that the ordinance was unconstitutionally over broad as applied. The Ninth Circuit
affirmed, but instead of finding that the ordinance was over broad, it concluded that the ordinance
was not narrowly tailored to serve a substantial governmental interest. The county presented no
evidence that a single showing of an adult movie would have any harmful secondary effects on the
community. It is clear that definitions must be interpreted to apply only to a category of
establishments that are associated with negative secondary effects, and a one time use of a building
for sale or presentation of sexually explicit fare does not bring it within that category. Use the term
"regularly" in the definitions of adult theatre, adult cabaret, adult performance or adult performance
center to eliminate the possibility of a "single use" interpretation like the one that lead to the
invalidation of the ordinance in Tollis. As Justice Scalia wrote in his concurring opinion in
FW/PBS, "regularly features" means "a continuous presentation of the sexual material as one of the
very objectives of the commercial enterprise. FW /PBS, Inc. v. City of Dallas, 493 U.S. 215, 260
(1990).
The ordinance that was upheld in Young defined an adult book store as an establishment
"having as a substantial or significant portion of its stock in trade distinguished or characterized by
an emphasis on matter depicting, describing are related to "specified anatomical areas," (as defined
below, or an establishment with a segment or section devoted to the sale or display of such
material." Young, 427 U.S. at 53, n. 5. The Court rejected a vagueness argument against the phrase
"characterized by an emphasis." Courts have rejected the argument that "substantial or significant
portion" is unconstitutionally vague. ILQ Invs. Inc. v. City of Rochester, 25 F.3d 1413 (8 Cir.
1994); Mom NPop's, Inc. v. City of Charlotte, 1998 U.S. App. LEXIS 20272 (4t Cir. 1998). Also
the phrases "major businesses" SDJ, Inc. v. City of Houston, 636 F.Supp.1359, 1376 (1986) and
"principle business purpose," Dumas v. City ofDallas, 648 F. Supp. 1061, 1079 (N.D. Texas 1986),
aff'd 837 F.2d 1298 (5 Cir. 1988), reversed on other grounds; FW /PBS, Inc. v. City of Dallas, 493
U.S. 215 (1990), have also been upheld.
Cities commonly seek to avoid ambiguity by using percentages to define adult uses. Many
of these efforts have failed, Therefore, it is advisable to use the Court tested language that has been
held not to be unconstitutionally vague, in lieu of a more precise percentage definitions. City of New
York v. Les Hommes, 724 N.E. 2d 368 (N.Y. 1999); Christy v. City of Ann Arbor, 824 F.2d 489 (6'
Cir. 1987); World Wide Video v. City of Tukwila, 816 P.2d 18 (Wash. 1991)
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* Reasonable Alternative Avenues of Communication — Generally a city may not use a
zoning ordinance to effectively preclude adult businesses from locating within the city. The
Supreme Court has not gone so far as requiring that every small city or village provide a zone in
which adult businesses may locate. Areas open for adult businesses immediately surrounding a
small city may provide reasonable alternative avenues for communication. In Schad v. Borough of
Mount Ephrain, 452 U.S. 61 (1981), the Supreme Court invalidated a zoning ordinance that
prohibited all live entertainment. The Borough suggested that the ordinance was not
unconstitutional because live entertainment in the form of nude dancing was available nearby,
although not within the corporate limits. The Court stated "this may very well be true, but the
Borough cannot avail itself of that argument in this case. There is no county wide zoning in Camden
County, and Mount Ephrain is free under state law to impose its own zoning restrictions, within
constitutional limits." Schad, 452 U.S. at 76. The question whether every community, regardless
of size or proximity to other available venues, must provide a zone for adult businesses is undecided.
In Keego Harbor Co. v. City of Keego Harbor, the Sixth Circuit cited the Schad decision and did
not find that all municipalities must provide an area for adult entertainment. Still the ordinance in
question passed by a city of only 3000 was invalidated because it had the effect of totally prohibiting
adult uses in the city. Keego Harbor Co. v. City of Keego Harbor, 657 F.2d 94 (6` Cir. 1981). The
New Jersey Supreme Court upheld the state statute that prohibited sexually oriented businesses from
locating within a 1000 feet of another sexually oriented business or other defined land uses, despite
the fact that the effect of the statute was to prohibit adult businesses from locating within the
township of Saddlebrook. The Court concluded that the available sites for adult businesses existed
within the surrounding vicinity. Township of Saddlebrook v. AB Family Ctr., 722 A.2d 530 (NJ
1999).
* Other Venues for Communicating Message — Zoning regulations do not generally impact
the other venues available for dissemination of free speech messages in the sexually oriented
business market. For instance, such messages are widely available in magazines such as Hustler and
Penthouse, cable television, telephone services and free internet sites. Of course, there are outlets
for illegal expression of constitutionally unprotected sexual contact including peep show booths, lap
dances and couch dances. The availability of sexually oriented expression and even pornographic
expression through other means does not justify the preclusion of adult businesses from a particular
community.
The most common form of zoning regulation is the dispersal method approved by the
Supreme Court in Young. This method requires adult businesses to be separated by a distance from
each other and from specified land uses, such as churches, schools and residential neighbors, and
from each other. If the regulation allows for reasonable alternative sights for such businesses, a
court will usually uphold such limitations as a valid exercise of a zoning power. For questions
about the standards to apply to your community on the issue whether enough land is available to
serve as a venue for sexually oriented expression, refer to the following cases: Woodall v. City of
El Paso, 49 F.3d 1120 (5 Cir. 1995); 955 F.2d 1305 (5 Cir. 1992); 950 F.2d 255 (5 Cir. 1995) -
a series of cases. Topanga Press, Inc. v. City of Los Angeles, 989 F.2d 1524 (9 Cir. 1993), cert.
denied 511 U.S. 1030 (1994); Seung Chun Lim v. City of Long Beach, 217 F.3d 1050 (9` Cir. 2000)
cert denied 121 S. Ct. 1189 (2001); Diamond vs. City of Taft, 215 F.3d 1052 (9 Cir. 2000).
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* Amortization of Non - Conforming Adult Uses — The Constitution does not require
indefinite "grandfathering" for sexually oriented businesses that become nonconforming uses, if the
ordinance provides for a reasonable amortization period recovery of investment. SDJ, Inc. v. City
of Houston, 636 F. Supp. 1359, 1370 (1986), aff'd, 837 F.2d 1268, 1278 (5 Cir. 1988); Dumas v.
City of Dallas, 648 F. Supp. 1061, 1171 (ND Tex. 1986), aff d 837 F.2d 1298 (5 Cir. 1988);
Rathkopf, THE LAW OF ZONING AND PLANNING, Chapter 17B (Clark Boardman Callaghan). In 23
West Washington Street, Inc. v. City of Hagerstown, 1992 U.S. App. LEXIS 18014 (4 Cir. 1992),
the City did not provide for grandfathering, or provide special exceptions for existing uses when a
new zoning ordinance was passed that affected sexually oriented businesses. The Court upheld the
ordinance because it provided for amortization provisions, which allowed the purposes of the
ordinance to reduce secondary effects of adult businesses.
Challenges to ordinances that do not contain amortization provisions, or that contain
amortization provisions with short time periods are often challenged. Such arguments often fail
because amortization of a nonconforming use does not generally render the property completely
worthless under the federal constitutional analysis. Ranchhouse, Inc. v. Amerson, 238 F.3d 1273
(11 Cir. 2001); NW Enters. v. City of Houston, 27 F. Supp. 2d 754, 865 (SD Tex. 1998). Court
opinions discuss the reasonableness of the amortization period in determining whether the
amortization clause should be upheld. To determine the appropriate length of an amortization period
in a particular community, the City must balance the substantial governmental interests advanced
by the ordinance with the need to provide a business a fair amount of time to recoup its investment.
Northend Cinema, Inc. v. City of Seattle, 585 P.2d 1153 (1978), cert. denied 441 U.S. 946 (1979).
Courts require a sexually oriented business to exhaust as administrative remedies before seeking
relief in state or federal court. An example is Stringfellow's of New York, Ltd. v. City of New York,
694 N.E. 2d 407, 420 (N.Y. 1998).
Typically conditional use ordinances operate as licensing schemes and allow the denial of
a use permit based on the zoning boards finding that the proposed use will have adverse effects upon
adjacent and surrounding uses. Since the negative secondary effects of adult businesses constitute
the very reason for regulating them more stringently than other land uses, some courts have
invalidated conditional use permitting schemes as applying to adult businesses. Landover Books,
Inc. v. Prince George's County, 566 A.2d 792 (Md. Ct. Spec. App. 1989); Dease v. City ofAnaheim,
826 F.Supp. 336 (C.D. Cal. 1993). That does not mean that cities may never place special
requirements on adult uses, but when they do so, objective standards and guidelines for the zoning
board to follow in deciding whether to grant or deny the permit, must be expressly established. 801
Conklin Street Ltd. v. Town of Babylon, 38 F.Supp.2d 228, 244 (E.D.N.Y. 1999).
4. Licensing
Some cities have abandoned permitting and licensing schemes altogether and allowed
sexually oriented businesses to open as a matter of right (as a permitted use) when certain objective
criteria are met. These criteria often include the distance restriction and operational standards. The
problem with this approach is that license or permit suspension and revocation is no longer available
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as an enforcement tool. The city only has civil and criminal proceedings available if a sexually
oriented business violates its ordinances.
The term "prior restraint" is used "to describe administrative and judicial orders forbidding
certain communications when issued in advance of the time that such communications are to occur."
Alexander v. United States, 509 U.S. 544, 550 (1993). The purpose of the prior restraint doctrine
is to prevent government censorship. O'Connor v. City and County ofDenver, 894 F.2d 1210, 1220
(10 Cir. 1990). Prior restraint must take place "under procedural safeguards designed to obviate
the dangers of a censorship system." Southeastern Promotions, Ltd. v. Conrad, 420 U.S. 546
(1975).
* Licensing Business Operations — In FW /PBS Inc. v. City ofDallas, cities have been given
some guidance as to what to avoid in licensing ordinances. Justice O'Connor's majority opinion
finds that censorship statutes where aimed at suppressing obscenity prior to its dissemination, rather
than prosecuting after dissemination. In the obscenity context, it is reasonable for courts to place
the burden of going forward on the government, because the government bears the burden of
initiating a prosecution. In the content neutral licensing context, however, placing burdens on the
government is not subject to the same analysis, provided that the standards for denying a license are
not based on unbridled discretion. The decisions are more or less administrative and not judicial.
There must be limitations on the time within which a city must issue the license, and prompt judicial
review must be available.
* Avoiding Unbridled Discretion — The Constitution requires any licensing requirement
for speech related activity to be governed by narrow, definite, and objective criteria in order to avoid
prior restraint problems. City of Lakewood v. Plain Dealer Publ'g Company, 486 U.S. 750 (1988).
Unbridled discretion in the hands of a government official to deny a license makes room for
censorship. The failure to place a time limit on when the licensing decision must be made also
results in censorship. If the ordinance is specific in spelling out what sexual acts and what parts of
the human body and what sexual toys qualify as sexual, then the ordinance can be upheld under the
constitutional challenge. Courts recognize that a "modicum of judgment" must be exercised by the
regulators. Baby Tam and Company, Inc. v. City of Las Vegas, 247 F.3d 1003 (9 Cir. 2001) (Baby
Tam III). An adult business ordinance must specify the time frame in which the licensing agency
must make a decision.
* Prompt Judicial Review — The Fourth, Sixth and Ninth circuits have held that when a city
denies a sexually oriented business license, the ordinance must guarantee a prompt judicial decision
on the merits of a challenge to the denial within a brief, specified period of time. 11126 Baltimore
Boulevard, Inc. v. Prince George's County, 58 F.3d 988 (4t Cir. 1995); Lounge Mgmt., Inc. v. City
ofPaducah, 202 F.3d 884 (6 Cir. 2000); Baby Tam & Company, Inc. v. City ofLas Vegas, 154 F.3d
1097 (9 Cir. 1998) (Baby Tam 1). The First, Fifth, Sixth and Eleventh circuits have held that the
prompt judicial review requirement is met if the ordinance allows for prompt access to the courts.
Jews for Jesus v. Massachusetts Bay Transp. Auth., 984 F.2d 1319 (1S Cir. 1993); TK's Video, Inc.
v. Denton County, 24 F.3d 705 (5 Cir. 1994); Graff v. City of Chicago, 9 F.3d 1309 (7 Cir. 1993)
(en banc); Boss Capital, Inc. v. City of Casselberry, 187 F.3d 1251 (11t Cir. 1999). Under FW /PBS,
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if a city cannot guarantee a prompt judicial decision, the enforcement of its license denial must be
stayed until a court has validated the denial. The problem with this approach is that the sexually
oriented business has no incentive to aggressively pursue an appeal of the denial, as it would have
the benefit of the permit for an indefinite period until a judicial decision is rendered. The Law in
the Firth Circuit provides that prompt access to the courts is required by an ordinance and if that is
provided, the licensed denial can be enforced in the interim. The Supreme Court may decide this
issue in the case of Thomas v. Chicago Park District, 227 F.3d 921 (7 Cir. 2000) rehearing denied,
for which certiorari has been granted. A potential solution would be for the cities to ask the
legislature to enact legislation mandating short time periods for state courts to resolve administrative
appeals. Such efforts have been successful in Nevada, California and Tennessee.
* Renewal Suspension and Revocation — The power to license necessarily includes the
power to revoke a license and the power not to renew a license. Still it would appear that decisions
to revoke or deny renewal of a previously issued license would seem to be analyzed under thof
content neutral steps provided in O'Brien, FW /PBS and the other major Supreme Court
announcements in this area. [In other words, if the revocation or non - renewal operates as a prior
restraint, then the full analysis applicable to such regulations must be applied to determine the
validity of the revocation or non - renewal.]
* License Fees — License fees charged to adult entertainment businesses must be reasonable,
must be "revenue neutral." Schultz v. City of Cumberland, 228 F.3d 831 (7 Cir. 2000). The fees
must be intended only to defray the costs of administering the ordinance. In general, the burden of
proving that a license fee is unreasonable is on the applicant for the license. Worldwide Video, Inc.
v. City of Tukwila, 816 P.2d 18 (Washington 1991); Adult Entm't Ctr., Inc. v. Pierce County, 788
P.2d 1102 (1990). Cities should avoid requiring a bond or license fee intended to remunerate
victims or the community for the expense of prosecutions associated with the operation of the
business. Such exactions have been held to excessively burden constitutional rights. Wendling v.
City of Duluth, 495 F. Supp. 1380 (D. Minn. 1980); American Target Advertising, Inc. v. Giani, 199
F.3d 1241 (10 Cir. 2000).
* Regulating Persons Involved in the Sexually Oriented Businesses — An application
for a license to operate a sexually oriented business should require applicants to disclose information
that is reasonably necessary (1) to identify and communicate with the applicant; and (2) to determine
whether a disqualification in the ordinance applies to the particular applicant. Under the
identification factor, courts have upheld requirements that the applicants provide their names,
addresses, identifying documents and documents that substantiate age. TK's Video, Inc. v. Denton
County, 24 F.3d 705 (5 Cir. 1994). Under the disqualification function, courts will uphold the
required disclosure of prior criminal conduct, if such conduct is a valid basis for a disqualifying
applicant. Schultz v. City of Cumberland, 228 F.3d 831 (7 Cir. 2000). Complete identification of
sexually oriented business employees is essential to preventing prostitution and other elicit sexual
activity. KEV, Inc. v. Kitsap County, 793 F.2d 1053 (9 Cir. 1986).
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* Regulating the Interior Premises - Stage and Booth Requirements — Cities have been
held to have a substantial interest in regulating the interior configurations of strip bars and dance
clubs. The Supreme Court has recognized that such establishments have repeated problems with
prostitution and other elicit activities. City of Erie v. Pap's A.M., 526 U.S. 277 (2000); Barnes v.
Glen Theatre, Inc., 501 U.S. 560 (1991). Some cities have enacted ordinances establishing buffer
zones or specified distances that must be maintained between entertainers and customers. These
have generally been upheld as valid manner restrictions on presentations of striptease. City of
Colorado Springs v. 2354 Inc., 896 P.2d 272; Colacurcio v. City of Kent, 163 F.3d 545 (9` Cir.
1998). To ensure compliance with configuration standards and other requirements, inspection
provisions are often included in sexually oriented business ordinances. Most courts have recognized
that there is an obvious need for inspections, and that a city's goal of preventing negative secondary
effects could be compromised without the ability to monitor compliance. New York v. Burger, 482
U.S. 691(1987); Allno Enterprises, Inc. v. Baltimore County, 2001 U.S. App. LEXIS 11522 (4 Cir.
2001).
* Vicarious Liability of Business Operators — Ordinances often impose either civil license
revocation or criminal sanctions on sexually oriented businesses for the unlawful acts of employees
and customers. In United States v. Park, 421 U.S. 658 (1975), the Supreme Court ruled that
imposing criminal liability for the acts of another does not necessarily require proof that the
responsible party lcnowingly permitted the illegal conduct. The Court has not decided what level
of knowledge (actual, constructive, or none) is a constitutional requirement before imprisonment
could be imposed. Staples v. United States, 511 U.S. 600 (1994). There is no constitutional obstacle
to imposing a fine upon a business operator for the acts of another on the premises. Lady J.
Lingerie, Inc. v. City of Jacksonville, 176 F.3d 1358 (1 1 Cir. 1999). Respondeat superior liability
could be applied to hold business operators responsible for employees under their scope of authority,
because the regulations involved are meant to deter activity that pose a special risk to public health
or safety, and are not traditional crimes. It would seem that the better practice would be to require
showing at least of negligence before imputing liability to a licensee for the conduct of others at the
business. Broadway Books, Inc. v. Roberts, 642 F. Supp. 486 (E.D. Tenn. 1986).
5. Other Types of Regulation
* Moratoria — Moratoria, as applied to speech related businesses, constitutes a clear restraint
on expressive activity and is greatly disfavored. Holmberg v. City of Ramsey, 12 F.3d 140 (8 Cir.
1994). The better practice is to simply follow normal procedures for granting a zoning permit and
to pass a more restrictive ordinance to meet a growing trend in the community. This type of
approach generally will not invalidate an otherwise valid ordinance. Threesome Entertainment v.
Strittmather, 4 F. Supp. 2d 710 (N.D. Ohio 1998); D.G. Rest. Corp. v. City of Myrtle Beach, 953
F.2d 140 (4` Cir. 1991).
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Some cities have adopted ordinances that restrict advertisement of tobacco products and
alcoholic beverages on billboards in areas where children congregate. Anheuser Busch, Inc. v.
Schmoke, and Penn Advertising v. Mayor and City Counsel of Baltimore, 101 F.3d 325 (4 Cir.
1996) cert. denied, 520 U.S. 1204 (1997). Arguably then similar restrictions on outdoor
advertisement of sexually oriented businesses could be justified. The argument would be that the
governmental interest in protecting children may justify special regulations.
* Hours of Operation — One of the simplest and most effective ways to regulate and abate
the negative secondary effects of sexually oriented businesses is through the restriction on hours of
operation. The Supreme Court has not specifically ruled on hours of operation limitations as applied
to these businesses but some Courts of Appeals have upheld them. Star Satellite, Inc. v. City of
Biloxi, 779 F.2d 1074 (5 Cir. 1986); Lady J. Lingerie, 176 F.3d at 1358. A significant case is
Mitchell v. Commission on Adult Entertainment Establishment, 10 F.3d 123 (3` Cir. 1993), where
the Court analyzed the Delaware statute regulating hours of operation of adult businesses. The Third
Circuit's applied the O'Bryan and Renton test and upheld the hours of operation restriction, which
prohibited opening of the businesses between 10:00 a.m. and 10:00 p.m. Monday through Saturday.
Five Courts of Appeals have adopted the Third Circuit's approach and have generally upheld the
restrictions. Nat'l Amusements v. Town of Dedham, 43 F.3d 731 (P Cir. 1995); Richland Book
Mart, Inc. v. Nichols, 137 F.3d 435 (6`h Cir. 1998); DiMa Corp. v. Town ofHallie, F.3d 823 (7
Cir. 1999); Lady J. Lingerie v. City of Jacksonville, 176 F.3d 1358 (11 Cir. 1999).
It is prudent to identify state law closing hours for sexually oriented businesses that hold
liquor licences to avoid potential conflicts with those state laws. One way to avoid a conflict would
be to draft the ordinance hours of operation restrictions in the manner that the community and the
City Council deems appropriate, and then include an exemption for liquor licensees to allow them
to operate during the hours that their liquor license allows.
6. Conclusion
The First Amendment imposes significant limitations on a local government's power to
regulate sexually oriented businesses and the land upon which they sit. City attorneys scramble to
consult with other city attorneys in other jurisdictions that have dealt with such businesses, and
borrow studies and copy ordinance language. The problem is that the sexually oriented business
industry= is well funded and sophisticated and always seems to be "ahead of the curve" in First
Amendment legal analysis. Clearly, small communities are the least likely to have the resources to
litigate issues.
Consider factoring the internet into the equation to determine whether a community has a
reasonable range of alternative sites for sexually oriented communication. If you want to adopt a
"pasties and G- string" ordinance, or an ordinance establishing the "newer" forms of operational
restrictions, create a solid record including accepted studies, assert specific findings and clarify an
express purpose to withstand the high level of judicial scrutiny applied to your ordinance. The local
government must be thoroughly prepared to support its actions in a case of legal challenge. There
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is a high cost involved in the litigation of alleged constitutional rights, including damages and
attorney's fees under 42 U.S.C. §§1983 and 1998. Uncertainties in the law require the practitioner
to study carefully and keep current with developments. In that regard, please refer to the appendix
attached to this paper.
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SOURCES
"Regulating Sexually Oriented Businesses," Thomas P. Brandt, Texas City Attorneys Association
Semi - Annual Summer Meeting (1997)
Local Regulation of Adult Businesses, Jules B. Gerard (2001)
Protectin Fg_ree Speech and Expression - The First Amendment and Land Use Law, Daniel R.
Mandelker and Rebecca L. Rubin, editors (2001)
"Smut, Smokes, and Spirits: The First Amendment Re- examined," Deborah J. Fox, The Urban
Lawyer, Vol. 32, No. 3 (Summer 2000)
"Nude Dancing and First Amendment Scrutiny," Anne E. Mitchell, The Urban Lawyer, Vol. 34, No.
1 (Winter 2002)
www.communitvdefense.org
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l
APPENDIX A
SAMPLE ORDINANCE PROVISIONS - NATIONAL FAMILY LEGAL FOUNDATION
NATIONAL FAMILY LEGAL FOUNDATION Page 1 of 24
SAMPLE SEXUALLY ORIENTED BUSINESS ORDINANCE
ORDINANCE NO.
AN ORDINANCE AMENDING THE ZONING ORDINANCE BY DISPERSING SEXUALLY
ORIENTED BUSINESSES AND LIMITING THEM TO A SPECIFIED ZONING DISTRICT;
PRESCRIBING DEFINITIONS OF SEXUALLY ORIENTED BUSINESSES; PROVIDING FOR
LICENSING AND REGULATION OF SEXUALLY ORIENTED BUSINESSES AND
EMPLOYEES; PROVIDING FOR ADDITIONAL MISCELLANEOUS REGULATIONS FOR
SEXUALLY ORIENTED BUSINESSES.
WHEREAS, sexually oriented businesses require special supervision from the public safety agencies of
the City in order to protect and preserve the health, safety, morals and welfare of the patrons of such
businesses as well as the citizens of the City; and
WHEREAS, the City Council finds that sexually oriented businesses are frequently used for unlawful
sexual activities, including prostitution and sexual liaisons of a casual nature; and
WHEREAS, the concern over sexually transmitted diseases is a legitimate health concern of the City
which demands reasonable regulation of sexually oriented businesses in order to protect the health and
well -being of the citizens; and
WHEREAS, licensing is a legitimate and reasonable means of accountability to ensure that operators of
sexually oriented businesses comply with reasonable regulations and to ensure that operators do not
knowingly allow their establishments to be used as places of illegal sexual activity or solicitation; and
WHEREAS, there is convincing documented evidence that sexually oriented businesses, because of
their very nature, have a deleterious effect on both the existing businesses around them and the
surrounding residential areas adjacent to them, causing increased crime and the downgrading of property
values; and
WHEREAS, it is recognized that sexually oriented businesses, due to their nature, have serious
objectionable operational characteristics, particularly when they are located in close proximity to each
other, thereby contributing to urban blight and downgrading the quality of life in the adjacent area; and
WHEREAS, the City Council desires to minimize and control these adverse effects and thereby protect
the health, safety, and welfare of the citizenry; protect the citizens from increased crime; preserve the
quality of fife; preserve the property values and character of surrounding neighborhoods and deter the
spread of urban blight; and
WHEREAS, the City Council has determined that locational criteria alone do not adequately protect the
health, safety, and general welfare of the people of this City; and
WHEREAS, it is not the intent of this ordinance to suppress any speech activities protected by the First
Amendment, but to enact a content neutral ordinance which addresses the secondary effects of sexually
oriented businesses; and
WHEREAS, it is not the intent of the City Council to condone or legitimize the distribution of obscene
material, and the Council recognizes that state and federal law prohibits the distribution of obscene
materials and expects and encourages state law enforcement officials to enforce state obscenity statutes
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against any such illegal activities in the City.
Pursuant to the authority granted by the Constitution and the legislature of the State of , BE IT
ENACTED BY THE CITY COUNCIL OF
, COUNTY, :
SECTION I. PURPOSE AND FINDINGS.
(A) Purpose. It is the purpose of this ordinance to regulate sexually oriented businesses in order to
promote the health, safety, morals, and general welfare of the citizens of the City, and to establish
reasonable and uniform regulations to prevent the deleterious location and concentration of sexually
oriented businesses within the City. The provisions of this ordinance have neither the purpose nor effect
of imposing a limitation or restriction on the content of any communicative materials, including sexually
oriented materials. Similarly, it is not the intent nor effect of this ordinance to restrict or deny access by
adults to sexually oriented materials protected by the First Amendment, or to deny access by the
distributors and exhibitors of sexually oriented entertainment to their intended market. Neither is it the
intent nor effect of this ordinance to condone or legitimize the distribution of obscene material.
(B) Findings. Based on evidence concerning the adverse secondary effects of adult uses on the
community presented in hearings and in reports made available to the Council, and on findings
incorporated in the cases of City of Renton v. Playtime Theatres, Inc., 475 U.S. 41 (1986), Young v.
American Mini Theatres, 426 U.S. 50 (1976), FW /PBS, Inc. v. City of Dallas, 493 U.S. 215 (1990);
Barnes v. Glen Theatre, Inc., 501 U.S. 560 (1991), City of Erie v. Pap's A.M., 120 S. Ct. 1382 (2000),
and on studies in other communities including, but not limited to, Phoenix, Arizona; Minneapolis,
Minnesota; St. Paul, Minnesota; Houston, Texas; Indianapolis, Indiana; Amarillo, Texas; Garden Grove,
California; Los Angeles, California; Whittier, California; Austin, Texas; Seattle, Washington; Oklahoma
City, Oklahoma; Cleveland, Ohio; Beaumont, Texas; Dallas, Texas; Newport News, Virginia; Bellevue,
Washington; New York, New York; and St. Croix County, Wisconsin; and also on findings from the
Report of the Attorney General's Working Group On The Regulation Of Sexually Oriented Businesses,
(June 6, 1989, State of Minnesota), the Council finds:
(1) Sexually oriented businesses lend themselves to ancillary unlawful and unhealthy activities that are
presently uncontrolled by the operators of the establishments. Further, there is presently no mechanism
to make the owners of these establishments responsible for the activities that occur on their premises.
(2) Certain employees of sexually oriented businesses defined in this ordinance as adult theatres and
cabarets engage in higher incidence of certain types of illicit sexual behavior than employees of other
establishments.
(3) Sexual acts, including masturbation, and oral and anal sex, occur at sexually oriented businesses,
especially those which provide private or semi - private booths or cubicles for viewing films, videos, or
live sex shows.
(4) Offering and providing such space encourages such activities, which creates unhealthy conditions.
(5) Persons frequent certain adult theatres, adult arcades, and other sexually oriented businesses for the
purpose of engaging in sex within the premises of such sexually oriented businesses.
(6) At least 50 communicable diseases may be spread by activities occurring in sexually oriented
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businesses, including, but not limited to, syphilis, gonorrhea, human immunodeficiency virus infection
(HIV- AIDS), genital herpes, hepatitis B, Non A, Non B amebiasis, salmonella infections and shigella
infections.
(7) Since 1981 and to the present, there has been an increasing cumulative number of reported cases of
AIDS caused by the human immunodeficiency virus (HIV) in the United States -- 600 in 198Z 2,200 in
1983, 4,600 in 1984, 8,555 in 1985 and 253,448 through December 31, 1992.
(8) As of , 200, there have been
reported cases of AIDS in the State of .
(9) Since 1981 and to the present, there have been an increasing cumulative number of persons testing
positive for the HIV antibody test in , .
(10) The number of cases of early (less than one year) syphilis in the United States reported annually has
risen, with 33,613 cases reported in 1982 and 45,200 through November of 1990.
(11) The number of cases of gonorrhea in the United States reported annually remains at a high level,
with over one -half million cases being reported in 1990.
(12) The surgeon general of the United States in his report of October 22, 1986, has advised the
American public that AIDS and HIV infection may be transmitted through sexual contact, intravenous
drug abuse, exposure to infected blood and blood components, and from an infected mother to her
newborn.
(13) According to the best scientific evidence, AIDS and HIV infection, as well as syphilis and
gonorrhea, are principally transmitted by sexual acts.
(14) Sanitary conditions in some sexually oriented businesses are unhealthy, in part, because the
activities conducted there are unhealthy, and, in part, because of the unregulated nature of the activities
and the. failure of the owners and the operators of the facilities to self - regulate those activities and
maintain those facilities.
(15) Numerous studies and reports have determined that semen is found in the areas of sexually oriented
businesses where persons view "adult" oriented films.
(16) The findings noted in paragraphs number 1 through 15 raise substantial governmental concerns.
(17) Sexually oriented businesses have operational characteristics which should be reasonably regulated
in order to protect those substantial governmental concerns.
(18) A reasonable licensing procedure is an appropriate mechanism to place the burden of that
reasonable regulation on the owners and the operators of the sexually oriented businesses. Further, such
a licensing procedure will place a heretofore nonexistent incentive on the operators to see that the
sexually oriented business is run in a manner consistent with the health, safety and welfare of its patrons
and employees, as well as the citizens of the City. It is appropriate to require reasonable assurances that
the licensee is the actual operator of the sexually oriented business, fully in possession and control of the
premises and activities occurring therein.
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(19) Removal of doors on adult booths and requiring sufficient lighting on premises with adult booths
advances a substantial governmental interest in curbing the illegal and unsanitary sexual activity
occurring in adult theatres.
(20) Requiring licensees of sexually oriented businesses to keep information regarding current
employees and certain past employees will help reduce the incidence of certain types of criminal
behavior by facilitating the identification of potential witnesses or suspects and by preventing minors
from working in such establishments.
(21) The disclosure of certain information by those persons ultimately responsible for the day -to -day
operation and maintenance of the sexually oriented business, where such information is substantially
related to the significant governmental interest in the operation of such uses, will aid in preventing the
spread of sexually transmitted diseases.
(22) It is desirable in the prevention of the spread of communicable diseases to obtain a limited amount
of information regarding certain employees who may engage in the conduct which this ordinance is
designed to prevent or who are likely to be witnesses to such activity.
(23) The fact that an applicant for an adult use license has been convicted of a sexually related crime
leads to the rational assumption that the applicant may engage in that conduct in contravention of this
ordinance.
(24) The barring of such individuals from the management of adult uses for a period of years serves as a
deterrent to and prevents conduct which leads to the transmission of sexually transmitted diseases.
(25) The general welfare, health, morals and safety of the citizens of the City will be promoted by the
enactment of this ordinance.
SECTION II. DEFINITIONS.
(1) ADULT ARCADE means any place to which the public is permitted or invited wherein coin -
operated or slug- operated or electronically, electrically, or mechanically controlled still or motion
picture machines, projectors, or other image - producing devices are regularly maintained to show images
to five or fewer persons per machine at any one time, and where the images so displayed are
distinguished or characterized by their emphasis upon matter exhibiting "specified sexual activities" or
"specified anatomical areas."
(2) ADULT BOOKSTORE, ADULT NOVELTY STORE OR ADULT VIDEO STORE means a
commercial establishment which has as a significant or substantial portion of its stock -in -trade or
derives a significant or substantial portion of its revenues or devotes a significant or substantial portion
of its interior business or advertising, or maintains a substantial section of its sales or display space for
the sale or rental, for any form of consideration, of any one or more of the following:
(a) books, magazines, periodicals or other printed matter, or photographs, films, motion pictures, video
cassettes, compact discs, slides, or other visual representations which are characterized by their
emphasis upon the exhibition or display of "specified sexual activities" or "specified anatomical areas ";
(b) instruments, devices, or paraphernalia which are designed for use or marketed primarily for
stimulation of human genital organs or for sadomasochistic use or abuse of themselves or others.
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(3) ADULT CABARET means a nightclub, bar, restaurant, or similar commercial establishment which
regularly features:
(a) persons who appear semi -nude; or
(b) live performances which are characterized by the exposure of "specified anatomical areas" or by
"specified sexual activities "; or
(c) films, motion pictures, video cassettes, slides or other photographic reproductions which are
characterized by the exhibition or display of "specified sexual activities" or "specified anatomical areas."
(4) ADULT MOTEL means a hotel, motel or similar commercial establishment which:
(a) offers accommodations to the public for any form of consideration; provides patrons with closed -
circuit television transmissions, films, motion pictures, video cassettes, slides, or other photographic
reproductions which are characterized by the exhibition or display of "specified sexual activities" or
"specified anatomical areas"; and has a sign visible from the public right of way which advertises the
availability of this adult type of photographic reproductions; and either
(b) offers a sleeping room for rent for a period of time that is less than ten (10) hours, or
(c) allows a tenant or occupant of a sleeping room to subrent the room for a period of time that is less
than ten (10) hours.
(5) ADULT MOTION PICTURE THEATER means a commercial establishment where, for any form of
consideration, films, motion pictures, video cassettes, slides, or similar photographic reproductions are
regularly shown which are characterized by the depiction or description of "specified sexual activities"
or "specified anatomical areas."
(6) ADULT THEATER means a theater, concert hall, auditorium, or similar commercial establishment
which regularly features persons who appear in a state of nudity or semi -nude, or live performances
which are characterized by the exposure of "specified anatomical areas" or by "specified sexual
activities."
(7) DISTINGUISHED OR CHARACTERIZED BY AN EMPHASIS UPON means the dominant or
principal theme of the object referenced. For instance, when the phrase refers to films "which are
distinguished or characterized by an emphasis upon the exhibition or display of Specified Sexual
Activities �r Specified Anatomical Areas," the films so described are those whose dominant or principal
character and theme are the exhibition or display "Specified Anatomical Areas" or "Specified Sexual
Activities."
(8) EMPLOYEE, EMPLOY, AND EMPLOYMENT describe and pertain to any person who performs
any service on the premises of a sexually oriented business, on a full time, part time, or contract basis,
regardless of whether the person is denominated an employee, independent contractor, agent, or other
status. Employee does not include a person exclusively on the premises for repair or maintenance of the
premises or for the delivery of goods to the premises.
(9) ENFORCEMENT OFFICER shall mean the City Zoning Administrator or such person as may be
designated by the City Council.
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(10) ESCORT means a person who, for consideration, agrees or offers to act as a companion, guide, or
date for another person, or who agrees or offers to privately model lingerie or to privately perform a
striptease for another person.
(11) ESCORT AGENCY means a person or business association who furnishes, offers to furnish, or
advertises to furnish escorts as one of its primary business purposes for a fee, tip, or other consideration.
(12) ESTABLISH OR ESTABLISHMENT means and includes any of the following:
(a) the opening or commencement of any sexually oriented business as a new business;
(b) the conversion of an existing business, whether or not a sexually oriented business, to any sexually
oriented business;
(c) the additions of any sexually oriented business to any other existing sexually oriented business; or
(d) the relocation of any sexually oriented business.
(13) LICENSEE means a person in whose name a license to operate a sexually oriented business has
been issued, as well as the individual listed as an applicant on the application for a license; and in the
case of an employee, a person in whose name a license has been issued authorizing employment in a
sexually oriented business.
(14) NUDITY or a STATE OF NUDITY means the showing of the human male or female genitals,
pubic area, vulva, anus, or anal cleft with less than a fully opaque covering, the showing of the female
breast with less than a fully opaque covering of any part of the nipple, or the showing of the covered
male genitals in a discernibly turgid state.
(15) OPERATE OR CAUSE TO BE OPERATED means to cause to function or to put or keep in a state
of doing business. "Operator" means any persons on the premises of a sexually oriented business who is
authorized to exercise operational control of the business or who causes to function or who puts or keeps
in operation the business. A person may be found to be operating or causing to be operated a sexually
oriented business regardless of whether that person is an owner, part owner, or licensee of the business.
(16) PERSON means an individual, proprietorship, partnership, corporation, association, or other legal
entity.
(17) SEMI =NUDE or in a SEMI -NUDE CONDITION means the showing of the female breast below a
horizontal line across the top of the areola at its highest point or the showing of the male or female
buttocks. This definition shall include the entire lower portion of the human female breast, but shall not
include any portion of the cleavage of the human female breast, exhibited by a dress, blouse, skirt,
leotard, bathing suit, or other wearing apparel provided the areola is not exposed in whole or in part.
(18) SEMI -NUDE MODEL STUDIO means any place where a person appears semi -nude and is
provided to be observed, sketched, drawn, painted, sculptured, or photographed by other persons who
pay money or any form of consideration. Nude Model Studio shall not include a proprietary school
licensed by the State of
or a college, junior college or university supported entirely or in part by public taxation; a private
college or university which maintains and operates educational programs in which credits are
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transferable to a college, junior college, or university supported entirely or partly by taxation; or in a
structure:
(a) that has no sign visible from the exterior of the structure and no other advertising that indicates a
nude or semi -nude person is available for viewing; and
(b) where in order to participate in a class a student must enroll at least three days in advance of the
class; and
(c) where no more than one nude or semi -nude model is on the premises at any one time.
(19) SEXUAL ENCOUNTER CENTER means a business or commercial establishment, that as one of
its principal business purposes, offers for any form of consideration, a place where two or more persons
may congregate, associate, or consort for the purpose of "specified sexual activities." The definition of
sexual encounter establishment or any sexually oriented businesses shall not include an establishment
where a medical practitioner, psychologist, psychiatrist, or similar professional person licensed by the
state engages in medically approved and recognized sexual therapy.
(20) SEXUALLY ORIENTED BUSINESS means an adult arcade, adult bookstore, adult novelty store,
adult video store, adult cabaret, adult motel, adult motion picture theater, adult theater, escort agency,
nude model studio, or sexual encounter center.
(21) SPECIFIED ANATOMICAL AREAS means: _
(a) the human male genitals in a discernibly turgid state, even if completely and opaquely covered; or
(b) less than completely and opaquely covered human genitals, pubic region, buttocks or a female breast
below a point immediately above the top of the areola.
(22) SPECIFIED CRIMINAL ACTIVITY means any of the following offenses:
(a) prostitution or promotion of prostitution; dissemination of obscenity; sale, distribution or display of
harmful material to a minor; sexual performance by a child; possession or distribution of child
pornography; public lewdness; indecent exposure; indecency with a child; engaging in organized
criminal activity relating to a sexually oriented business; sexual assault; molestation of a child; or
distribution of a controlled substance; or any similar offenses to those described above under the
criminal or penal code of other states or countries;
(b) for which:
(1) less than two years have elapsed since the date of conviction or the date of release from confinement
imposed for the conviction, whichever is the later date, if the conviction is of a misdemeanor offense;
(2) less than five years have elapsed since the date of conviction or the date of release from confinement
for the conviction, whichever is the later date, if the conviction is of a felony offense; or
(3) less than five years have elapsed since the date of the last conviction or the date of release from
confinement for the last conviction, whichever is the later date, if the convictions are of two or more
misdemeanor offenses or combination of misdemeanor offenses occurring within any 24 -month period.
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(c) The fact that a conviction is being appealed shall have no effect on the disqualification of the
applicant or a person residing with the applicant.
(23) SPECIFIED SEXUAL ACTIVITIES means any of the following:
(a) the fondling of another person's genitals, pubic region, anus, or female breasts;
(b) sex acts, normal or perverted, actual or simulated, including intercourse, oral copulation,
masturbation, or sodomy; or
(c) excretory functions as part of or in connection with any of the activities set forth in (a) through (b)
above.
(24) SUBSTANTIAL ENLARGEMENT of a sexually oriented business means the increase in floor
areas occupied by the business by more than twenty -five percent (25 %), as the floor areas exist on the
date this ordinance takes effect.
(25) TRANSFER OF OWNERSHIP OR CONTROL of a sexually oriented business means and includes
any of the following:
(a) the sale, lease, or sublease of the business;
(b) the transfer of securities which constitute a controlling interest in the business, whether by sale,
exchange, or similar means; or
(c) the establishment of a trust, gift, or other similar legal device which transfers the ownership or
control of the business, except for transfer by bequest or other operation of law upon the death of the
person possessing the ownership or control.
SECTION III. CLASSIFICATION.
Sexually oriented businesses are classified as follows:
(1) adult arcades;
(2) adult bookstores, adult novelty stores, or adult video stores;
(3) adult cabarets;
(4) adult motels;
(5) adult motion picture theaters;
(6) adult theaters;
(7) escort agencies;
(8) semi -nude model studios; and
(9) sexual encounter centers.
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SECTION IV. LICENSE REQUIRED.
(A) It is unlawful:
(1) For any person to operate a sexually oriented business without a valid sexually oriented business
license issued by the City pursuant to this ordinance.
(2) For any person who operates a sexually oriented business to employ a person to work for the
sexually oriented business who is not licensed as a sexually oriented business employee by the City
pursuant to this ordinance.
(3) For any person to obtain employment with a sexually oriented business without having secured a
sexually oriented business employee license pursuant to this ordinance.
(B) An application for a license must be made on a form provided by the City. All applicants must be
qualified according to the provisions of this ordinance.
(C) An applicant for a sexually oriented business license or a sexually oriented business employee
license shall file with the Enforcement Officer a completed application made on a form prescribed and
provided by the City Treasurer. An application shall be considered complete if it includes the
information required in this section. The applicant shall be qualified according to the provisions of this
chapter. The application shall be notarized. The application shall include the information called for in
Paragraphs 1 through 6 as follows:
(1) The full true name and any other names used in the preceding five years.
1. Current business address.
(3) Either a set of fingerprints suitable for conducting necessary background checks pursuant to this
Chapter or the applicant's Social Security Number to be used for the same purpose .
(4) If the application is for a sexually oriented business license, the name, business location, legal
description, business mailing address and phone number of the proposed sexually oriented business.
(5) Written proof of age, in the form of either (a) a copy of a birth certificate and current photo, (b)
current driver's license with picture, or (c) other picture identification document issued by a
governmental agency.
(6) The issuing jurisdiction and the effective dates of any license or permit held by the applicant relating
to a sexually oriented business, whether any such license or permit has been denied, revoked or
suspended and, if so, the reason or reasons therefor.
(7) If the application is for a sexually oriented business license, the name and address of the statutory
agent or other agent authorized to receive service of process. The information provided pursuant to
Paragraphs 1 through 7 of this subsection shall be supplemented in writing by certified mail, return
receipt requested, to the Enforcement Officer within ten (10) working days of a change of circumstances
which would render the information originally submitted false or incomplete.
(D) The application for a sexually oriented business license shall be accompanied by a sketch or diagram
showing the configuration of the premises, including a statement of total floor space occupied by the
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business. The sketch or diagram need not be professionally prepared but shall be drawn to a designated
scale or drawn with marked dimensions of the interior of the premises to an accuracy of plus or minus
six inches.
(E) If a person who wishes to operate a sexually oriented business is an individual, he shall sign the
application for a license as applicant. If a person who wishes to operate a sexually oriented business is
other than an individual, such as a corporation, each officer, director, general partner or other person
who will participate directly in decisions relating to management of the business shall sign the
application for a license as applicant. Each applicant must be qualified under Section V and each
applicant shall be considered a licensee if a license is granted.
(F) A person who possesses a valid business license is not exempt from the requirement of obtaining any
required sexually oriented business license. A person who operates a sexually oriented business and
possesses a business license shall comply with the requirements and provisions of this Chapter, where
applicable.
(G) The information provided by an applicant in connection with the application for a license under this
chapter shall be maintained by the Enforcement Officer on a confidential basis, and may be disclosed
only: (1) to other governmental agencies in connection with a law enforcement or public safety function,
or (2) as may otherwise be required by law or court order.
SECTION V. ISSUANCE OF LICENSE.
(A) Upon the filing of a completed application for a sexually oriented business license or a sexually
oriented business employee license, the Enforcement Officer shall issue a Temporary License to the
applicant, which Temporary License shall expire upon the final decision of the Enforcement Officer to
deny or grant the license. Within (20) days after the receipt of a completed application, the Enforcement
Officer shall either issue a license or issue a written notice of intent to deny a license to the applicant.
The Enforcement Officer shall approve the issuance of a license unless one or more of the following is
found to be true:
(1) An applicant is less than eighteen (18) years of age.
(2) An applicant is delinquent in the payment to the city of taxes, fees, fines, or penalties assessed
against or imposed upon the applicant in relation to a sexually oriented business.
(3) An applicant has failed to provide information as required by Section IV for issuance of the license.
(4) An applicant; a business entity for which the applicant had, at the time of an offense leading to a
criminal conviction described herein, a management responsibility or a controlling interest, has been
convicted of a specified criminal activity as defined in this chapter. The fact that a conviction is being
appealed shall have no effect.
(5) The license application fee required by this section has not been paid.
(6) An applicant has falsely answered a question or request for information on the application form.
(7) The proposed sexually oriented business is located in a zoning district other than a district in which
sexually oriented businesses are allowed to operate under the Zoning Ordinance or is not in
compliance with the location restrictions established for sexually oriented businesses in the appropriate
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zoning district(s).
(B) An applicant ineligible for a license due to Paragraph (A)(4) of this section may qualify for a
sexually oriented business license only when the time period required by the applicable paragraph has
elapsed.
(C) The license, if granted, shall state on its face the name of the person or persons to whom it is
granted, the number of the license issued to that applicant, the expiration date, and, if the license is for a
sexually oriented business, the address of the sexually oriented business. A sexually oriented business
employee license shall contain a photograph of the licensee. The sexually oriented business license shall
be posted in a conspicuous place at or near the entrance to the sexually oriented business so that it may
be easily read at any time. A sexually oriented business employee shall keep the employee's license on
his or her person or on the premises where the licensee is then working or performing and shall produce
such license for inspection upon request by a law enforcement officer or other authorized city official.
SECTION VI. FEES.
(A) The nonrefundable initial license fee and annual renewal fee for a sexually oriented business license
or a sexually oriented business employee license shall be set by the City Council at an amount
determined to be sufficient to pay the cost of administering this program, subject to section (B) herein.
(B) In no event shall the fees exceed two hundred fifty dollars ($250.00) for the initial license and one
hundred twenty five dollars ($125.00) for the renewal fee for a sexually oriented business license. In no
event shall the fees exceed one hundred dollars ($100.00) for the initial license and fifty dollars ($50.00)
for the renewal fee for a sexually oriented business employee license.
SECTION VII. INSPECTION.
(A) An applicant, operator or licensee shall permit law enforcement officers, and any other federal, state,
county or city agency in the performance of any function connected with the enforcement of this
Chapter, normally and regularly conducted by such agencies, to inspect those portions the premises of a
sexually oriented business where patrons or customers are permitted to occupy for the purpose of
ensuring compliance with this chapter, at any time the business is occupied or open for business.
(B) The provisions of this Section do not apply to areas of an adult motel which are currently being
rented by a customer for use as a permanent or temporary habitation.
SECTION VIII. EXPIRATION OF LICENSE.
(A) Each license shall expire one year from the date of issuance and may be renewed only by making
application as provided in Section IV. Application for renewal shall be made at least thirty (30) days
before the expiration date, and when made less than thirty (30) days before the expiration date, the
expiration of the license will not be affected.
(B) When the City denies renewal of a license, the applicant shall not be issued a license for one year
from the date of denial. If, subsequent to denial, the City finds that the basis for denial of the renewal
license has been corrected or abated, the applicant shall be granted a license if at least ninety (90) days
have elapsed since the date denial became final.
SECTION IX. SUSPENSION.
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(A) The City shall issue a written intent to suspend a license for a period not to exceed thirty (30) days if
it determines that a licensee or an employee of a licensee has:
(1) violated or is not in compliance with any section of this ordinance;
(2) refused to allow an inspection of the sexually oriented business premises as authorized by this
chapter.
SECTION X. REVOCATION.
(A) The Enforcement Officer shall issue a written statement of intent to revoke a sexually oriented
business license if a cause of suspension in Section IX occurs and the license has been suspended within
the preceeding twelve (12) months.
(B) The Enforcement Officer shall issue a written statement of intent to revoke a sexually oriented
business license if the Officer determines that:
(1) a licensee gave false or misleading information in the material submitted during the application
process;
(2) a licensee has knowingly allowed possession, use, or sale of controlled substances on the premises;
(3) a licensee has knowingly allowed prostitution on the premises;
(4) a licensee knowingly operated the sexually oriented business during a period of time when the
licensee's license was suspended;
(5) a licensee has knowingly allowed any act of sexual intercourse, sodomy, oral copulation,
masturbation, or other sex act to occur in or on the licensed premises. This subsection will not apply to
an adult motel, unless the licensee knowingly allowed sexual sexual activities to occur either (a) in
exchange for money, or (a) in a public place or within public view.
(C) The fact that a conviction is being appealed shall have no effect on the revocation of the license.
(D) When, after the notice and hearing procedure described in Section XI, the Enforcement Officer
revokes a license, the revocation shall continue for one (1) year and the licensee shall not be issued a
sexually oriented business license for one (1) year from the date revocation becomes effective, provided
that, if the conditions of Section XI(B) are met, a Provisional License will be granted pursuant to that
section. If, subsequent to revocation, the Enforcement Officer finds that the basis for the revocation
found in subsections (B)(1) and (B)(4) of this section has been corrected or abated, the applicant shall be
granted a license if at least ninety (90) days have elapsed since the date the revocation became effective.
SECTION XI. HEARING; LICENSE DENIAL, SUSPENSION,
REVOCATION; APPEAL.
(A) If the Enforcement Officer determines that facts exist for denial, suspension, or revocation of a
license under this chapter, the Enforcement Officer shall notify the applicant or licensee (respondent) in
writing of the intent to deny, suspend or revoke the license, including the grounds therefor, by personal
delivery, or by certified mail. The notification shall be directed to the most current business address on
file with the Enforcement Officer. Within five (10) working days of receipt of such notice, the
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respondent may provide to the City Manager in writing a response that shall include a statement of
reasons why the license or permit should not be denied, suspended, or revoked. Within three (3) days of
the receipt of respondent's written response, the City Manager shall notify respondent in writing of the
hearing date on respondent's denial, suspension, or revocation proceeding.
Within ten (10) working days of the receipt of respondent's written response, the City Manager shall
conduct a hearing at which respondent shall have the opportunity to be represented by counsel and
present evidence and witnesses on his or her behalf. If a response is not received by the City Manager in
the time stated or, if after the hearing the City Manager finds that grounds as specified in this resolution
exist for denial, suspension, or revocation, then such denial, suspension, or revocation shall become final
five (5) days after the City Manager sends, by certified mail, written notice that the license has been
denied, suspended, or revoked. Such notice shall include a statement advising the applicant or licensee
of the right to appeal such decision to a court of competent jurisdiction.
If the City Manager finds that no grounds exist for denial, suspension, or revocation of a license, then
within five (5) days after the hearing, the City Manager shall withdraw the intent to deny, suspend, or
revoke the license and shall so notify the respondent in writing by certified mail of such action and shall
contemporaneously therewith issue the license.
(B) When a decision to deny, suspend or revoke a license becomes final, the applicant or licensee
(aggrieved party) whose application for a license has been denied or whose license has been suspended
or revoked shall have the right to appeal such action to a court of competent jurisdiction. Upon the filing
of any court action to appeal, challenge, restrain or otherwise enjoin the City's enforcement of the
denial, suspension, or revocation, the City shall immediately issue the aggrieved party a Provisional
License. The Provisional License shall allow the aggrieved party to continue operation of the sexually
oriented business or to continue employment as a sexually oriented business employee and will expire
upon the court's entry of a judgment on the aggrieved party's action to appeal, challenge, restrain or
otherwise enjoin the City's enforcement.
SECTION XII. TRANSFER OF LICENSE.
A licensee shall not transfer his/her license to another, nor shall a licensee operate a sexually oriented
business under the authority of a license at any place other than the address designated in the
application.
SECTION XIII. LOCATION OF SEXUALLY ORIENTED BUSINESSES.
(A) A person commits a misdemeanor if that person operates or causes to be operated a sexually
oriented business in any zoning district other than
, as defined and described in the zoning code.
(B) A person commits an offense if the person operates or causes to be operated a sexually oriented
business within feet of:
(1) A church, synagogue, mosque, temple or building which is used primarily for religious worship and
related religious activities;
(2) A public or private educational facility including but not limited to child day care facilities, nursery
schools, preschools, kindergartens, elementary schools, private schools, intermediate schools, junior
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high schools, middle schools, high schools, vocational schools, secondary schools, continuation schools,
special education schools, junior colleges, and universities; school includes the school grounds, but does
not include facilities used primarily for another purpose and only incidentally as a school;
(3) A boundary of a residential district as defined in the
zoning code;
(4) A public park or recreational area which has been designated for park or recreational activities
including but not limited to a park, playground, nature trails, swimming pool, reservoir, athletic field,
basketball or tennis courts, pedestrian/bicycle paths, wilderness areas, or other similar public land within
the city which is under the control, operation, or management of the city park and recreation authorities;
(5) The property line of a lot devoted to a residential use as defined in the zoning code;
(6) An entertainment business which is oriented primarily towards children or family entertainment; or
(7) A licensed premises, licensed pursuant to the alcoholic beverage control regulations of the State.
(C) A person commits a misdemeanor if that person causes or permits the operation, establishment,
substantial enlargement, or transfer of ownership or control of a sexually oriented business within feet of
another sexually oriented business.
(D) A person commits a misdemeanor if that person causes or permits the operation, establishment, or
maintenance of more than one sexually oriented business in the same building, structure, or portion
thereof, or the increase of floor area of any sexually oriented business in any building, structure, or
portion thereof containing another sexually oriented business.
(E) For the purpose of subsection B of this Section, measurement shall be made in a straight line,
without regard to the intervening structures or objects, from the nearest portion of the building or
structure used as the part of the premises where a sexually oriented business is conducted, to the nearest
property line of the premises of a use listed in subsection B. Presence of a city, county or other political
subdivision boundary shall be irrelevant for purposes of calculating and applying the distance
requirements of this Section.
(F) For purposes of subsection C of this Section, the distance between any two sexually oriented
businesses shall be measured in a straight line, without regard to the intervening structures or objects or
political boundaries, from the closest exterior wall of the structure in which each business is located.
(G) Any sexually oriented business lawfully operating on , 200_, that is in violation of subsection A
through F of this Section shall be deemed a nonconforming use. The nonconforming use will be
permitted to continue for a period not to exceed one year, unless sooner terminated for any reason or
voluntarily discontinued for a period of thirty (30) days or more. Such nonconforming uses shall not be
increased, enlarged, extended, or altered except that the use may be changed to a conforming use. If two
or more sexually oriented businesses are within feet of one another and otherwise in a permissible
location, the sexually oriented business which was first established and continually operating at a
particular location is the conforming use and the later established business(es) is /are nonconforming.
(H) A sexually oriented business lawfully operating as a conforming use is not rendered a
nonconforming use by the location, subsequent to the grant or renewal of the sexually oriented business
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license, of a use listed in subsection B of this Section within feet of the sexually oriented business. This
provision applies only to the renewal of a valid license, and does not apply when an application is made
for a license after the applicant's previous license has expired or been revoked.
SECTION XIV. REGULATIONS PERTAINING TO
EXHIBITION OF SEXUALLY EXPLICIT FILMS, VIDEOS OR
LIVE ENTERTAINMENT IN VIEWING ROOMS.
(A) A person who operates or causes to be operated a sexually oriented business, other than an adult
motel, which exhibits on the premises in a viewing room of less than one hundred fifty (150) square feet
of floor space, a film, video cassette, live entertainment, or other video reproduction which depicts
specified sexual activities or specified anatomical areas, shall comply with the following requirements:
(1) Upon application for a sexually oriented license, the application shall be accompanied by a diagram
of the premises showing a plan thereof specifying the location of one or more manager's stations and the
location of all overhead lighting fixtures and designating any portion of the premises in which patrons
will not be permitted. A manager's station may not exceed thirty -two (32) square feet of floor area. The
diagram shall also designate the place at which the permit will be conspicuously posted, if granted. A
professionally prepared diagram in the nature of an engineer's or architect's blueprint shall not be
required; however, each diagram should be oriented to the north or to some designated street or object
and should be drawn to a designated scale or with marked dimensions sufficient to show the various
internal dimensions of all areas of the interior of the premises to an accuracy of plus or minus six (6 ")
inches. The City may waive the foregoing diagram for renewal applications if the applicant adopts a
diagram that was previously submitted and certifies that the configuration of the premises has not been
altered since it was prepared.
(2) The application shall be sworn to be true and correct by the applicant.
(3) No alteration in the configuration or location of a manager's station may be made without the prior
approval of the City.
(4) It is the duty of the licensee of the premises to ensure that at least one licensed employee is on duty
and situated in each manager's station at all times that any patron is present inside the premises.
(5) The interior of the premises shall be configured in such a manner that there is an unobstructed view
from a manager's station of every area of the premises to which any patron is permitted access for any
purpose, excluding restrooms. Restrooms may not contain video reproduction equipment. If the
premises has two or more manager's stations designated, then the interior of the premises shall be
configured in such a manner that there is an unobstructed view of each area of the premises to which any
patron is permitted access for any purpose from at least one of the manager's stations. The view required
in this subsection must be by direct line of sight from the manager's station.
(6) It shall be the duty of the licensee to ensure that the view area specified in subsection (5) remains
unobstructed by any doors, curtains, partitions, walls, merchandise, display racks or other materials and,
at all times, to ensure that no patron is permitted access to any area of the premises which has been
designated as an area in which patrons will not be permitted in the application filed pursuant to
subsection (1) of this Section.
(7) No viewing room may be occupied by more than one person at any time.
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(8) The premises shall be equipped with overhead lighting fixtures of sufficient intensity to illuminate
every place to which patrons are permitted access at an illumination of not less than five (5.0) foot -
candles as measured at the floor level.
(9) It shall be the duty of the licensee to ensure that the illumination described above is maintained at all
times that any patron is present in the premises.
(10) No licensee shall allow openings of any kind to exist between viewing rooms or booths.
(11) No person shall make or attempt to make an opening of any kind between viewing booths or rooms.
(12) The licensee shall, during each business day, regularly inspect the walls between the viewing
booths to determine if any openings or holes exist.
(13) The licensee shall cause all floor coverings in viewing booths to be nonporous, easily cleanable
surfaces, with no rugs or carpeting.
(14) The licensee shall cause all wall surfaces and ceiling surfaces in viewing booths to be constructed
of, or permanently covered by, nonporous, easily cleanable material. No wood, plywood, composition
board or other porous material shall be used within forty eight (48 ") inches of the floor.
(B) A person having a duty under Subsection (1) through (14) of Subsection (A) above commits a
misdemeanor if he knowingly fails to fulfill that duty.
SECTION XV. ADDITIONAL REGULATIONS FOR ESCORT AGENCIES.
(A) An escort agency shall not employ any person under the age of 18 years.
(B) A person commits an offense if the person acts as an escort or agrees to act as an escort for any
person under the age of 18 years.
SECTION XVI. ADDITIONAL REGULATIONS CONCERNING PUBLIC NUDITY.
(A) It shall be a misdemeanor for a person who knowingly and intentionally, in a sexually oriented
business, appears in a state of nudity or engages in specified sexual activities.
(B) It shall be a misdemeanor for a person who knowingly or intentionally in a sexually oriented
business appears in a semi -nude condition unless the person is an employee who, while semi -nude, shall
be at least six (6) feet from any patron or customer and on a stage at least two feet from the floor.
(C) It shall be a misdemeanor for an employee, while semi -nude in a sexually oriented business, to
receive directly any pay or gratuity from any patron or customer or for any patron or customer to pay or
give any gratuity directly to any employee, while said employee is semi -nude in a sexually oriented
business.
(D) It shall be a misdemeanor for an employee, while semi -nude, to knowingly and intentionally touch a
customer or the clothing of a customer.
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SECTION XVII. PROHIBITION AGAINST CHILDREN IN A
SEXUALLY ORIENTED BUSINESS.
A person commits a misdemeanor if the person knowingly allows a person under the age of 18 years on
the premises of a sexually oriented business.
SECTION XVIII. HOURS OF OPERATION.
No sexually oriented business, except for an adult motel, may remain open at any time between the
hours of one o'clock (1:00) A.M. and eight o'clock (8:00) A.M. on weekdays and Saturdays, and one
o'clock (1:00) A.M. and noon (12:00) P.M. on Sundays.
SECTION XIX. EXEMPTIONS.
(A) It is a defense to prosecution under Section XVII that a person appearing in a state of nudity did so
in a modeling class operated:
(1) by a proprietary school, licensed by the State of ; a college, junior college, or university supported
entirely or partly by taxation;
(2) by a private college or university which maintains and operates educational programs in which
credits are transferable to a college, junior college, or university supported entirely or partly by taxation;
or
(3) in a structure:
(a) which has no sign visible from the exterior of the structure and no other advertising that indicates a
nude person is available for viewing; and
(b) where, in order to participate in a class a student must enroll at least three (3) days in advance of the
class; and
(c) where no more than one nude model is on the premises at any one time.
SECTION XX. INJUNCTION. •
A person who operates or causes to be operated a sexually oriented business without a valid license or in
violation of Section XII of this ordinance is subject to a suit for injunction as well as prosecution for
criminal violations. Such violations shall be punishable by a fine of $200.00 or thirty (30) days
imprisonment. Each day a sexually oriented business so operates is a separate offense or violation.
SECTION XXI. SEVERABILITY.
Each section and provision of this ordinance are hereby declared to be independent divisions and
subdivisions and, not withstanding any other evidence of legislative intent, it is hereby declared to be the
controlling legislative intent that if any provisions of said chapter, or the application thereof to any
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person or circumstance is held to be invalid, the remaining sections or provisions and the application of
such sections and provisions to any person or circumstances other than those to which it is held invalid,
shall not be affected thereby, and it is hereby declared that such sections and provisions would have
been passed independently of such section or provision so known to be invalid.
SECTION XXII. CONFLICTING ORDINANCES REPEALED.
All ordinances or parts of ordinances in conflict with the provisions of this ordinance are hereby
repealed.
SECTION XXIII. EFFECTIVE DATE.
This ordinance shall be enforced from and after , 200_.
MEMORANDUM OF LAW
SUPPORTING SAMPLE COMPREHENSIVE SOB ORDINANCE
DISCLAIMER
As noted in Footnote 1, the Sample Ordinance, because of its comprehensive nature, necessarily
contains regulatory provisions that will not work in each jurisdiction. Courts have applied a myriad of
nuances to the analysis of adult business restrictions, and each local ordinance requires jurisdiction -
specific research and drafting. The purpose of this memorandum is to provide the general legal basis for
the provisions found in the sample ordinance. It is a brief outline of the law, not an exhaustive treatise.
The ordinance is a "time, place, and manner regulation." As such, it is "content neutral" and focuses on
the negative secondary consequences or harmful effects of sexually oriented businesses. For a full
discussion of adult business regulations, please consult CDC's legal manual, available online at
www.conununitydefense.or /g legalmanual.cfm.
INTRODUCTION
There are five U.S. Supreme Court decisions which every practitioner should read before drafting a local
ordinance regulating adult businesses: Young v. American Mini Theatres, Inc., 427 U.S. 50 (1976); City
of Renton v. Playtime Theatres, Inc., 475 U.S. 41 (1986); FW /PBS, Inc. v. City of Dallas, 493 U.S. 215
(1990); Barnes v. Glen Theatre, Inc., 501 U.S. 560 (1991); and City of Erie v. Pap's A.M., 120 S. Ct.
1382.
In Young, the Supreme Court upheld the constitutionality of a Detroit zoning ordinance regulating the
location of "adult" theatres by prohibiting them from locating within 1000 feet of any two other
regulated uses or within 500 feet of a residential area. A plurality of the Court found that the Detroit
ordinance did not violate the First Amendment as an impermissible prior restraint, and that the ordinance
was based on a substantial governmental interest.
In Renton, the Supreme Court again upheld the constitutionality of a city's zoning ordinance against a
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NATIONAL FAMILY LEGAL FOUNDATION Page 19 of 24
First Amendment challenge. The challenged ordinance was designed to regulate adult uses by
prohibiting them from locating within 1000 feet of any residential zone, single- or multiple - family
dwelling, church, park or school. Because the ordinance did not prohibit these uses altogether, the Court
analyzed the city's ordinance as a form of time, place and manner regulation. "[C]ontent- neutral' time,
place, and manner regulations are acceptable so long as they are designed to serve a substantial
governmental interest and do not unreasonably limit alternate avenues of communication." 475 U.S. at
47. This ordinance, the Court stated, was aimed at the secondary effects of adult uses, and not at the
content of the films shown, and was clearly based on a substantial interest in preventing crime,
protecting retail trade, and maintaining property values. The ordinance was also narrowly tailored to
"affect only that category of theaters shown to produce the unwanted secondary effects." Id. at 52.
Further, the Court found that the ordinance allowed for reasonable alternative avenues of
communication because it left 520 acres or more than 5 percent of the entire land area of Renton
available for adult uses. "In our view, the First Amendment requires that Renton refrain from effectively
denying Respondents a reasonable opportunity to open and operate an adult theater within the city." Id.
at 54.
The ordinance contains not only zoning regulations, but also licensing requirements, regulations dealing
with "peep booths or arcades," hours of operation restrictions, and other miscellaneous regulations
directed at neutralizing the negative secondary effects of sexually oriented businesses. Subsequent cases
to Young and Renton have analyzed these additional regulations, over and above zoning regulations,
pursuant to the same time, place and manner analysis that is found in Renton. Using this analysis, these
additional regulations have consistently been upheld against constitutional challenge.
DISCUSSION
The following is a review and discussion of important provisions found within the ordinance:
(1) Legislative Findings. The preamble and purpose sections of the ordinance are lengthy and detailed.
Unlike other ordinances, courts frequently look at the purported purpose, legislative findings, and intent
behind a sexually oriented business ordinance to determine whether it is indeed content neutral or if it is
simply a pretext for attempting to eliminate or suppress adult uses. Therefore, the legislative body must
make specific findings supporting the need for the ordinance and demonstrating that the ordinance is
content neutral and directed at the negative secondary effects of adult businesses rather than the sexually
explicit nature of the materials or performances offered within.
A city must establish that its sexually oriented business zoning and licensing ordinances are reasonable,
i.e., that there is a need for them. It may conduct studies regarding its own experience with sexually
oriented businesses. But not every city has the resources to conduct its own studies. After Renton, it is
not necessary for a city to conduct its own studies. It may rely on the experiences and studies of other
cities. 475 U.S. at 50.
To determine whether an ordinance is reasonable, a court must look to the legislative record. There must
be evidence in the record to support the ordinance. Fortunately, as the ordinance demonstrates, there is
significant and sufficient evidence on which a legislature may rely to prove the reasonableness of an
adult business ordinance like this one. Thus, a city council may obtain studies or reports conducted by
other cities and rely on them in enacting the ordinance. Many such studies are available and may be
obtained from planning directors of those cities, or from the CDC Law Library, located at
www. co mmunitydefense .org/seffects.cfm.
Renton held that a city need not show that a particular sex business causes the identified harmful
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secondary consequences. There was no showing that any particular use in Renton caused the secondary
consequences sought to be prevented. Again, a city or legislature may rely on the experiences of other
communities.
(2) Definitions. The definitions used in this ordinance are generally adopted from Young, Renton, and
FW /PBS, Inc. v. City of Dallas, 493 U.S. 215 (1990). Rather than to arbitrarily attempt to set a
percentage of use such as floor area, stock and trade, or gross revenues to define a sexually oriented
business, a more flexible approach has been approved by the Supreme Court. Language upheld by the
Supreme Court in Young was: "a substantial or significant portion of its stock in trade "; in Renton,
"distinguished or characterized by an emphasis on matter depicting, describing, or relating to [sex]." See
also People v. Superior Court, 259 Cal.Rep. 740 (1989), "one of its principle business purposes ".
Challenges to time, place, and manner regulations are frequently made on grounds that the language in
such laws is unconstitutionally vague. A majority of such challenges have been rejected. Because zoning
must apply to property uses which by nature are dynamic and changeable, you cannot define regulated
uses with absolutely scientific precision. The definitions used in this ordinance have been upheld against
vagueness challenges, although practitioners should research the law in their own jurisdictions before
implementing its provisions.
(3) Licensing. This Ordinance provides for licensing of both the sexually oriented business and
employees within. Licensing of the sexually oriented business is important to keep track of various adult
uses regulated under the zoning provisions and also to help document the negative secondary effects of
these uses. Licensing of both sexually oriented businesses and their employees is important to provide
for accountability -- i.e., who is responsible for what takes place on the premises, who truly owns the
establishment, and what is the background of workers and employees. However, drafting an effective
licensing scheme is a fairly complicated task and requires precise drafting to avoid constitutional
infirmities.
The Supreme Court has stated that cities can have special licensing schemes for different kinds of
speech activities: "Of course, the city may even have special licensing procedures for conduct
commonly associated with expression ." City of Lakewood v. Plain Deals Publishing Co., 486 U.S. 750,
760 (1988) (in the context of newsrack regulation).
Licensing schemes are routinely challenged on prior restraint grounds. In FW /PBS, the Court found that
a licensing requirement was a prior restraint and that certain safeguards were necessary to avoid
constitutional problems: (1) "the licensor must make the decision whether to issue the license within a
specified and reasonable time period during which the status quo is maintained," and (2) "there must be
the possibility of prompt judicial review in the event that the license is erroneously denied." 493 U.S. at
228.
A licensing scheme must establish clear guidelines limiting the discretion of the issuer to ensure that
protected speech is not suppressed. Further, those guidelines and the information required from
applicants must be reasonably related to the license's purpose. See, for example, Broadway Books, Inc.
v. Roberts, 642 F. Supp. 486 (E.D. Tenn. 1986); and Kev, Inc. v. Kitsap, Co., 793 F.2d 1053 (9th Cir.
1986) (upholding licensing requirements); but see Schultz v. City of Cumberland, 2000 U.S. App.
LEXIS 23773 (7 Cir. 2000) (upholding some disclosure requirements but invalidating others).
The plurality opinion in FW /PBS failed to define what is required to satisfy "prompt judicial review"
under a content neutral licensing scheme of sexually oriented businesses. The Fourth, Sixth, and Ninth
Circuits have held that a prompt judicial determination from a court of law must be assured, whereas the
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First, Fifth, Seventh, and Eleventh Circuits have held that for licensing ordinances, "prompt judicial
review" means access to prompt judicial review. See Jews for Jesus v. Massachusetts Bay
Transportation Authority, 984 F.2d 1319 (1 Cir. 1993); TK's Video v. Denton County, 24 F.3d 705 (5
Cir. 1994); Graff v. City of Chicago, 9 F.3d 1309 (7 Cir. 1993); but see, 11126 Baltimore Boulevard,
Inc. v. Prince George's County, 58 F.3d 988 (4 Cir. 1995); East Brooks Books, Inc. v. City of
Memphis, 48 F.3d 220 (6 Cir. 1995).
On June 19, 2000 the Supreme Court granted certiorari in a case that will likely answer the prompt
judicial review question and resolve the split in the circuits. City News & Novelty, Inc. v. City of
Waukesha, 231 Wis. 2d 93 (Wisc. Ct. App. 1999), cert. granted, 68 U.S.L.W. 3773 (June 19, 2000) (No.
99- 1680).
(4) Fees. Licensing fees to cover the cost of issuing and enforcing regulations are permissible, as long as
the fee is "revenue neutral." Cox v. New Hampshire, 312 U.S. 569 (1941). As long as the fee only
recoups the government's costs in providing a service and conducting any investigations and is not a tax
imposed on the exercise ofonstitutional right, it is constitutional.
The amount of the various fees is determined on a city -by -city basis and needs to be related to the
expenses (i.e., administrative costs, inspection expenses, law enforcement resources, etc.) incurred. But
a city need not show precisely its costs of administration, World Wide Video, Inc. v. Tukwila, 816 P.2d
18 (1991), and the burden is on the challenger to show that the fee is excessive. Adult Ent. Ctr., Inc. v.
Pierce Co., 788 P. 2d 1102, 1108 (1990).
(5) Zoning. The ordinance regulates the location of sexually oriented businesses by dispersing them
from each other and from other sensitive uses (residential area, parks, schools, churches, etc.) and
limiting them to one or more specified zoning districts. Scatter zoning was specifically approved of in
Renton, and Young employed both setbacks and dispersal features within commercial zones. 427 U.S. at
62.
"Cities may regulate adult theatres by dispersing them, as in Detroit, or by effectively concentrating
them, as in Renton. `It is not our function to appraise the wisdom of [the city's] decision to require adult
theatres to be separated rather than concentrated in the same areas ... [T]he city must be allowed a
reasonable opportunity to experiment with solutions to admittedly serious problems'." Renton, 475 U.S.
at 52.
The zone (or zones) that a sexually oriented business is to be limited to, and the amount of distance
between an adult business and other adult businesses or other sensitive uses, need to be determined by
each individual community based on its size (both geographic and population), number of sexually
oriented businesses presently existing, and the configuration of its present ,zoning scheme. The
locational restrictions will be constitutional so long as they allow for "reasonable alternative avenues of
communication ". Id. at 47.
Since Renton, various courts have upheld percentages below Renton's 5 percent as reasonable. See S &
G News, Inc. v. City of Southgate, 638 F. Supp. 1060 (E.D. Mich. 1986) (2.3 percent of the total land
area of the County) and Function Junction, Inc. v. City of Dayton Beach, 507 F. Supp. 544, 552 (M.D.
Fla. 1987) ("12 locations in Daytona Beach ... potentially could accommodate plaintiffs' [adult use]
lounges. ") The Fifth Circuit in Lakeland Lounge v. City of Jackson, 973 F. 2d 1255 (1992), found
reasonable a City of Jackson ordinance which provided for four areas with 8 to 10 locations which were
"available and suitable" -- approximately 1.2 percent of the City's land mass.
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(6) Amortization. One of the most important elements of "adult" use zoning ordinances is a requirement
that all nonconforming uses come into compliance within a specified period of time. A majority of the
states, and the U.S. Constitution, permit an ordinance to terminate pre- existing adult uses which conflict
with the locational or other provisions of an adult use zoning ordinance. Over a relatively brief period of
time, all nonconforming sexually oriented businesses are eliminated under such a requirement. In states
which allow amortization, pre- existing adult use status does not guarantee a permanent right to continue
such property use when it contravenes the requirements of an ordinance.
Amortization clauses are upheld if the time frame is reasonable. See Hart Bookstores, Inc. v. Edmisten,
612 F.2d 821 (4th Cir. 1979) (upheld ordinance providing a six -month amortization period for pre-
existing, nonconforming adult uses); Northend Cinema, Inc. v. City of Seattle, 585 P.2d 1153 (1978)
(upheld ordinance providing a 90 -day amortization period for pre- existing, nonconforming sex theaters);
Castner v. City of Oakland, 180 Cal. Rptr. 682 (1982) (upheld ordinance regulating adult entertainment
activity providing a one -year amortization period under which owner can apply for up to a two -year
extension); City of Vallejo v. Adult Books, 219 Cal. Rptr. 143 (1985) (upheld ordinance regulating adult
bookstores and theaters providing a one -year amortization period under which owners could apply for an
extra year if they could show extreme hardship); Cook County v. Renaissance Arcade, 522 N.E. 2d 73
(Ill. 1988) (upheld ordinance providing a six-month amortization period under which an additional six
months is given to any business which applies), and SDJ, Inc. v. City of Houston, 636 F. Supp. 1359
(S.D. Tex. 1986), affd. 841 F.2d 107 (5th Cir. 1988) (upheld six -month amortization of sexually
oriented businesses).
The amortization period provided for in the ordinance is one year. This one year period can be shortened
or lengthened depending on the case law in your jurisdiction and the factual situation existing in your
community, i.e., how many nonconforming sex uses already exist, how much do they have invested in
their present location, etc. Another common approach includes setting forth a specific period with the
option of an additional period if a hardship is demonstrated.
Amortization provisions contained in sexually oriented business zoning ordinances are constitutionally
permissible so long as they are content neutral and satisfy the requirements of Renton and Young, that
being, they must be "reasonable" and not "arbitrary and capricious." As noted, the state constitution
must allow for amortization generally.
(7) Arcade .Areas. The ordinance includes additional regulations pertaining to so- called "peep show"
booths. Ordinances regulating the interior configuration of sexually oriented businesses, more
particularly "peep show" booths, are routinely upheld against constitutional attack. However, it is
essential that a city council have before it some evidence (not necessarily as to its own experience, but in
"peep show "" booths generally based on others' experiences) of the sexual activities occurring within the
"peep show" booths. These reports should set forth information about sexual activity, such as
anonymous sex between patrons using "glory holes," masturbation, and other illicit activities. The
Supreme Court described the activity which occurred within "peep show" booths in Arcara v. Cloud
Books, Inc., 478 U.S. 697, 699 (1986): "The court reported evidence that such a booth was used for
`masturbation, fondling, and fellatio by patrons on the premises of the store ... "'. With such evidence or
documentation, the ordinance will rest upon a reasonable basis, and not be considered arbitrary or
capricious.
The following cases have upheld interior configuration requirements substantially identical or similar to
the model language contained herein, which provides for open booths with direct line of sight from a
manager's station: Wall Distributors, Inc. v. City of Newport News, Virginia, 782 F. 2d 1165 (4th Cir.
1986); Ellwest Stereo Theatres, Inc. v. Weiner, 681 F. 2d 1243 (9th Cir. 1982); Bamon Corp. v. City of
Dayton, 923 F.2d 470 (6th Cir. 1991).
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(8) Public Nudity. In 1991, the Supreme Court settled the question of whether communities can ban
public nude dancing in establishments not licensed to sell liquor, and without the added regulatory
power of the 21st Amendment. In Barnes v. Glen Theatre, Inc., 501 U.S. 560, 115 L.Ed. 2d 504, the
Supreme Court upheld the use of Indiana's public indecency law to prohibit nudity in a public place,
including an "adults only" sexually oriented business.
The Barnes Court emphasized that the Indiana law was not aimed at the suppression of free expression,
but was a content neutral prohibition of certain conduct: "The perceived evil that Indiana seeks to
address is not erotic dancing, but public nudity." Id. at 514. The Court found that Indiana's statute was
not directed at nude dancing or its potential expressive elements; rather, the State sought to prohibit
public nudity across the board.
In City of Erie v. Pap's A.M., 120 S. Ct. 1382 (2000), the Supreme Court reaffirmed its holding in
Barnes and further concluded that attacks on the individual motives of legislators who voted for a nudity
ban are constitutionally irrelevant: "As we have said before, however, this Court will not strike down an
otherwise constitutional statute on the basis of an alleged illicit motive." Id. at 1392 -93. For a more
complete discussion of the Pap's case, please see "City of Erie v. Pap's A.M. and the Future of Sexually
Oriented Business Regulation," by Scott D. Bergthold, Municipal Lawyer, Sept. /Oct. 2000, pp. 6 -9.
Section XVI prohibits total nudity in a sexually oriented business, pursuant to Barnes and Pap's. Also,
in Subsection B, the ordinance requires that individuals appearing in a "semi -nude condition" must be at
least 6 feet from any patron or customer and on a stage at least two feet from the floor, and that a semi-
nude employee may not solicit or be paid a gratuity, or touch a patron. Similar regulations were
approved in KEV, Inc. v. Kitsap County, 793 F. 2d 1053 (9th Cir. 1986), Hang On, Inc. v. City 01
Arlington, 65 F.3d 1248 (5th Cir. 1995), and DLS, Inc. v. City of Chattanooga, 123 F.3d 420 (6th Cir.
1997).
(9) Hours of Operation. The Ordinance's zoning provisions are "place" regulations. The licensing and
interior configuration requirements are "manner" regulations. Section XVIII is a "time" regulation.
Numerous courts have upheld hours of operation restrictions on sexually oriented businesses, which are
valid if they are narrowly tailored to advance a substantial government interest, such as the prevention of
crime and disturbances during the overnight hours. See e.g., Mitchell v. Commission on Adult
Entertainment, 10 F. 3d 123 (3d Cir. 1993); Star Satellite, Inc. v. City of Biloxi, 779 F.2d 1074 (5 Cir.
1986); Ben Rich Trading, Inc. v. City of Vineland, 126 F.3d 155 (3d Cir. 1997); National Amusements v.
Town of Dedham, 43 F.3d 731 (1 Cir. 1995); Richland Bookman, Inc. v. Nichols, 137 F.3d 435 (6th
1998); DiMa Corp. v. Town of Hallie, 185 F.3d 823 (7 Cir. 1999); Lady Lingerie v. City of
Jacksonville, 176 F.3d 1358 (11 Cir. 1999); L.J. Concepts, Inc. v. City of Phoenix, No. 99-
17270/17271 (9 Cir. 2000) (unpublished opinion).
However, a community should take care to avoid possible preemption problems for those sexually
oriented businesses that hold liquor licenses and whose hours may already be controlled by state law.
See e.g., J.L. Spoons, Inc. v. City of Brunswick, 49 F. Supp.2d 1032 (N.D. Ohio 1999) (determining that
local closing hours are preempted by state law).
CONCLUSION
This memorandum of law is not an exhaustive treatment of sexually oriented business and First
Amendment law, but rather an overview to demonstrate support for the various provisions found within
this sample ordinance. Because state and local laws vary, please consult with a local attorney before
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NATIONAL FAMILY LEGAL FOUNDATION Page 24 of 24
implementing this ordinance. For further details and assistance, please contact Community Defense
Counsel at 480 - 922 -9731 or contact us online at www.communitydefense.org.
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APPENDIX B
CASES TO READ
United States v. O'Brien, 391 U.S. 367 (1968)
Young v. American Mini - Theatres, Inc., 427 U.S.50 (1976)
City of Renton v. Playtime Theatres, Inc., 475 U.S. 41 (1986)
FW /PBS, Inc. v. City of Dallas, 493 U.S. 215 (1990)
City of Erie v. Pap's A.M., 529 U.S. 277 (2000)
Alameda Books, Inc. v. City of Los Angeles, 122 S. Ct. 1728; 2002 U.S. LEXIS 3424(2002)
(attached)
.:
Page Page
CITY OF LOS ANGELES, PETITIONER v. ALAMEDA BOOKS, INC., ET AL.
00 -799
SUPREME COURT OF THE UNITED STATES
122 S. Ct. 1728; 2002 U.S. LEXIS 3424; 70 U.S.L.W. 4369; 15 Fla. L. Weekly Fed. S 267
December 4, 2001, Argued
May 13, 2002, Decided
.(**1). The Ninth Circuit affirmed on the different ground
that, even if the ordinance were content neutral, the
The LEXIS pagination of this document is subject to city failed to present evidence upon which it could
change pending release of the final published version. reasonably rely to demonstrate that its regulation of
PRIOR HISTORY: ON WRIT OF CERTIORARI multiple -use establishments was designed to serve its
TO THE UNITED STATES COURT OF APPEALS substantial interest in reducing crime. The court
FOR THE NINTH CIRCUIT. therefore held the ordinance invalid under Renton v.
Playtime Theatres, Inc., 475 U.S. 41, 723 -724.
DISPOSITION: 222 F.3d 719, reversed and
remanded. Held: The judgment is reversed, and the case is
SYLLABUS: Based on its 1977 study concluding that remanded. 222 F.3d 719, reversed and remanded.
concentrations of adult entertainment establishments JUSTICE O'CONNOR, joined by THE CHIEF
are associated with higher crime rates in surrounding JUSTICE, JUSTICE SCALIA, and JUSTICE
communities, petitioner city enacted an ordinance THOMAS, concluded that Los Angeles may
prohibiting such enterprises within 1,000 feet of each reasonably rely on its 1977 study to demonstrate that
other or within 500 feet of a religious institution, its present ban on multiple -use adult establishments
school, or public park. Los Angeles Municipal Code § serves its interest in reducing crime. Pp. 5 -15.
12.70(C) (1978). Because the ordinance's method of (a) The 1977 study's central component is a Los
calculating distances created a loophole permitting the Angeles Police Department report indicating that, from
concentration of multiple adult enterprises in a single 1965 to 1975, crime rates for, e.g., robbery and
structure, the city later amended the ordinance to
prohibit "more than one adult entertainment business in prostitution grew much faster in Hollywood, which had
the same building." § 12.70(C) (1983). Respondents, the city's largest concentration of adult establishments,
two adult establishments that openly operate combined than in the city as a whole. The city may reasonably
rely on the police department's conclusions regarding
bookstores /video arcades in violation of § 12.70(C), as crime patterns to overcome summary judgment. In
amended, sued under 42 U. S. C. § 1983 for finding to the contrary on the ground that the 1977
declaratory and injunctive relief, alleging that the study focused on the effect on crime rates of a
ordinance, on its face, violates the First Amendment.
Finding that the ordinance was not a content-neutral concentration of establishments- -not a concentration of
regulation of speech, the District Court reasoned that operations within a single establishment- -the Ninth
neither the 1977 study nor a report cited in Hart Book Circuit misunderstood the study s implications. While
Stores v. Edmisten, a Fourth Circuit case upholding a the study reveals that areas with high concentrations of
similar statute, supported a reasonable belief that adult establishments are associated with high crime
multiple-use adult establishments rates, such areas are also areas with high
multi
p produce the concentrations of adult operations, albeit each in
secondary effects the city asserted as content - neutral separate establishments. It was therefore consistent
justifications for its prohibition. Subjecting § 12.70(C) with the 1977 study's findings, and thus reasonable, for
to strict scrutiny, the court granted respondents
summary judgment because it felt the city had not the city to infer that reducing the concentration of adult
offered evidence demonstrating that its prohibition was operations in a neighborhood, whether within separate
necessary to serve a compelling government interest.
establishments or in one large establishment, will
4
reduce crime rates. Neither the Ninth Circuit nor associated with adult businesses by exercising its
respondents nor the dissent provides any reason to zoning power, and at the same time leave the quantity
question the city's theory. If this Court were to accept and accessibility of speech substantially undiminished,
their view, it would effectively require that the city there is no First Amendment objection, even if the
provide evidence that not only supports the claim that measure identifies the problem outside the
its ordinance serves an important government interest, establishments by reference to the speech inside - -that
but also does not provide support for any other is, even if the measure is content based. On the other
approach to serve that interest. Renton specifically hand, a city may not regulate the secondary effects of
refused to set such a high bar for municipalities that speech by suppressing the speech itself. For example, it
want to address merely the secondary effects of may not impose a content -based fee or tax, see
protected speech. The Court there held that a Arkansas Writers' Project, Inc. v. Ragland, 481 U.S.
municipality may rely on any evidence that is 221, 230, even if the government purports to justify the
"reasonably believed to be relevant" for demonstrating fee by reference to secondary effects, see Forsyth
a connection between speech and a substantial, County v. Nationalist Movement, 505 U.S. 123, 134 -
independent government interest. 475 U.S. at 51 -52. 135. That the ordinance at issue is more a typical land -
This is not to say that a municipality can get away with use restriction than a law suppressing speech is
shoddy data or reasoning. The municipality's evidence suggested by the fact that it is not limited to expressive
must fairly support its rationale for its ordinance. If activities, but extends, e.g., to massage parlors, which
plaintiffs fail to cast direct doubt on this rationale, the city has found to cause the same undesirable
either by demonstrating that the municipality's secondary effects; also, it is just one part of an
evidence does not support its rationale or by fumishing elaborate web of land -use regulations intended to
evidence that disputes the municipality's factual promote the social value of the land as a whole without
findings, the municipality meets the Renton standard. If suppressing some activities or favoring others. Thus,
plaintiffs succeed in casting doubt on a municipality's the ordinance is not so suspect that it must be subjected
rationale in either manner, the burden shifts back to the to the strict scrutiny that content -based laws demand in
municipality to supplement the record with evidence other instances. Rather, it calls for intermediate
renewing support for a theory that justifies its scrutiny, as Renton held. Pp. 2 -5.
ordinance. See, e.g., Erie v. Pap's A. M., 529 U.S. (b) Renton's description of an ordinance similar to Los
277, 298. This case is at a very early stage in this Angeles' as "content neutral," 475 U.S. at 48, was
process. It arrives on a summary judgment motion by something of a fiction. These ordinances are content
respondents defended only by complaints that the 1977 based, and should be so described. Nevertheless,
study fails to prove that the city's justification for its Renton's central holding is sound. Pp. 5 -6.
ordinance is necessarily correct. Therefore, it must be
concluded that the city, at this stage of the litigation, (c) The necessary rationale for applying intermediate
has complied with Renton's evidentiary requirement. scrutiny is the promise that zoning ordinances like the
Pp. 5 -14. one at issue may reduce the costs of secondary effects
(b) The Court need not resolve the parties' dispute without substantially reducing speech. If two adult
over whether the city can rely on evidence from Hart businesses are under the same roof, an ordinance
requiring them to separate will have one of two results:
Book Stores to overcome summary judgment, nor
respondents' alternative argument that the ordinance is One business will either move elsewhere or close. The
not a time, place, and manner regulation, but is city's premise cannot be the latter. The premise must be
that businesses- -even those that have always been
effectively a ban on adult video arcades that must be under one roof- -will for the most part disperse rather
subjected to strict scrutiny. Pp. 14 -15. than shut down, that the quantity of speech will be
JUSTICE KENNEDY concluded that this Court's substantially undiminished, and that total secondary
precedents may allow Los Angeles to impose its effects will be significantly reduced. As to whether
regulation in the exercise of the zoning authority, and there is sufficient evidence to support this proposition,
that the city is not, at least, to be foreclosed by the Court has consistently held that a city must have
summary judgment. Pp. 1 -10. latitude to experiment, at least at the outset, and that
(a) Under Renton v. Playtime Theatres, Inc., 475 very little evidence is required. See, e.g., Renton,
U.S. 41, if a city can decrease the crime and blight supra, at 51 -52. Here, the proposition to be shown is
supported by common experience and a study showing
5
a correlation between the concentration of adult interpreting that case. 222 F.3d 719, 723 -728 (2000).
establishments and crime. Assuming that the study We reverse and remand. The city of Los Angeles may
supports the city's original dispersal ordinance, most of reasonably rely on a study it conducted some years
the necessary analysis follows. To justify the ordinance before enacting the present version of § 12.70(C) to
at issue, the city may infer- -from its study and from its demonstrate that its ban on multiple -use adult
own experience —that two adult businesses under the establishments serves its interest in reducing crime.
same roof are no better than two next door, and that
knocking down the wall between the two would not
ameliorate any undesirable secondary effects of their In 1977, the city of Los Angeles conducted a
proximity to one another. If the city's first ordinance comprehensive study of adult establishments and
was justified, therefore, then the second is too. Pp. 6- concluded that concentrations of adult businesses are
10. associated with higher rates of prostitution, robbery,
(d) Because these considerations seem well enough assaults, and thefts in surrounding communities. See
App. 35 -162 (Los Angeles Dept. of City Planning,
established in common experience and the Court's case Study of the Effects of the Concentration of Adult
law, the ordinance survives summary judgment. P. 10. Entertainment Establishments in the City of Los
JUDGES: O'CONNOR, J., announced the judgment of Angeles (City Plan Case No. 26475, City Council File
the Court and delivered an opinion, in which No. 74- 4521 -S.3, June 1977)). Accordingly, the city
REHNQUIST, C. J., and SCALIA and THOMAS, JJ., enacted an ordinance prohibiting the establishment,
joined. SCALIA, J., filed a concurring opinion. substantial enlargement, or transfer { * *12} of
KENNEDY, J., filed an opinion concurring in the ownership of an adult arcade, bookstore, cabaret,
judgment. SOUTER, J., filed a dissenting opinion, in motel, theater, or massage parlor or a place for sexual
which STEVENS and GINSBURG, JJ., joined, and in encounters within 1,000 feet of another such enterprise
which BREYER, J., joined as to Part II. or within 500 feet of any religious institution, school,
OPINIONBY• O'CONNOR or public park. See Los Angeles Municipal Code §
• 12.70(C) (1978).
OPINION: JUSTICE O'CONNOR announced the There is evidence that the intent of the city council
judgment of the { * *10} Court and delivered an when enacting this prohibition was not only to disperse
opinion, in which THE CHIEF JUSTICE, JUSTICE distinct adult establishments housed in separate
SCALIA, and JUSTICE THOMAS join.
buildings, but also to disperse distinct adult businesses
Los Angeles Municipal Code § 12.70(C) (1983), as operated under common ownership and housed in a
amended, prohibits "the establishment or maintenance single structure. See App. 29 (Los Angeles Dept. of
of more than one adult entertainment business in the City Planning, Amendment -- Proposed Ordinance to
same building, structure or portion thereof." Prohibit the Establishment of More than One Adult
Respondents, two adult establishments that each Entertainment Business at a Single Location (City Plan
operated an adult bookstore and an adult video arcade Case No. 26475, City Council File No. 82 -0155, Jan.
in the same building, filed a suit under Rev. Stat. § 13, 1983)). The ordinance the city enacted, however,
1979, 42 U.S.C. § 1983 (1994 ed., Supp. V), alleging directed that "the distance between any two adult
that § 12.70(C) violates the First Amendment and entertainment businesses shall be measured in a
seeking declaratory and injunctive relief. The District straight line ... from the closest exterior structural wall
Court granted summary judgment to respondents, of each business." Los Angeles Municipal Code §
fmding that the city of Los Angeles' prohibition was a 12.70(D) (1978). Subsequent to enactment, the city
content -based regulation of speech that failed strict realized that this method of calculating distances
scrutiny. The Court of Appeals for the Ninth Circuit created a loophole permitting { * *13} the
affirmed, but on different grounds. It held that, even if concentration of multiple adult enterprises in a single
§ 12.70(C) were a content - neutral regulation, the city structure.
failed to demonstrate that the prohibition was designed Concerned that allowing an adult - oriented department
to serve a substantial government interest. Specifically, store to replace a strip of adult establishments could
the Court of Appeals found that the city failed to defeat the goal of the original ordinance, the city
present evidence upon which it could reasonably rely
to demonstrate { * *11} a link between multiple -use council amended § 12.70(C) by adding a prohibition on
adult establishments and negative secondary effects.
"the establishment or maintenance of more than one
Therefore, the Court of Appeals held the Los Angeles adult entertainment business in the same building,
prohibition on such establishments invalid under structure or portion thereof." Los Angeles Municipal
Renton v. Playtime Theatres, Inc., 475 U.S. 41, 89 L. Code § 12.70(C) (1983). The amended ordinance
Ed. 2d 29 106 S. Ct. 925 198 defines an "Adult Entertainment Business" as an adult
( 6), and its precedents arcade, bookstore, cabaret, motel, theater, or massage
parlor or a place for sexual encounters, and notes that The District Court for the Central District of
each of these enterprises "shall constitute a separate California initially denied both motions on the First
adult entertainment business even if operated in Amendment issues in count I, concluding that there
conjunction with another adult entertainment business was "a genuine issue of fact whether the operation of a
at the same establishment." § 12.70(B)(17). The combination video rental and video viewing business
ordinance uses the term "business" to refer to certain leads to the harmful secondary effects associated with
types of goods or services sold in adult establishments, a concentration of separate businesses in a single urban
rather than the establishment itself. Relevant for area." App. 255. After respondents filed a motion for
purposes of this case are also the ordinance's reconsideration, however, the District Court found that
definitions of adult bookstores and arcades. An "Adult Los Angeles' prohibition on { * *16} multiple -use adult
Bookstore" is an operation that "has as a substantial establishments was not a content - neutral regulation of
portion of its stock -in -trade { * *14} and offers for speech. App, to Pet. for Cert. 51. It reasoned that the
sale" printed matter and videocassettes that emphasize neither the city's 1977 study nor a retort cited in Hart
the depiction of specified sexual activities. § Book Stores v. Edmisten, 612 F.2d 821 (CA4 1979)
12.70(B)(2)(a). An adult arcade is an operation where, (upholding a North Carolina statute that also banned
"for any form of consideration," five or fewer patrons multiple -use adult establishments), supported a
together may view films or videocassettes that reasonable belief that multiple -use adult establishments
emphasize the depiction of specified sexual activities. produced the secondary effects the city asserted as
§ 12.70(B)(1).
content - neutral justifications for its prohibition. App.
Respondents, Alameda Books, Inc., and Highland to Pet. for Cert. 34-47. Therefore, the District Court
Books, Inc., are two adult establishments operating in proceeded to subject the Los Angeles ordinance to
Los Angeles. Neither is located within 1,000 feet of strict scrutiny. Because it felt that the city did not offer
another adult establishment or 500 feet of any religious evidence to demonstrate that its prohibition is
institution, public park, or school. Each establishment necessary to serve a compelling government interest,
occupies less than 3,000 square feet. Both respondents the District Court granted summary judgment for
rent and sell sexually oriented products, including respondents and issued a permanent injunction
videocassettes. Additionally, both provide booths enjoining the enforcement of the ordinance against
where patrons can view videocassettes for a fee. respondents. Id., at 51.
Although respondents are located in different The Court of Appeals for the Ninth Circuit affirmed,
buildings, each operates its retail sales and rental although on different grounds. The Court of Appeals
operations in the same commercial space in which its determined that it did not have to reach the District
video booths are located. There are no physical
distinctions between the different operations within Court's decision that the Los Angeles ordinance was
each establishment and each establishment has only content based because, {**17} even if the ordinance
one entrance. 222 F.3d 719 at 721. Respondents were content neutral, the city failed to present evidence
concede they are { * *15} openly operating in violation upon which it could reasonably rely to demonstrate
of § 12.70(C) of the city's Code, as amended. Brief for that its regulation 1 of multiple -use establishments is
Respondents 7; Brief for Petitioner 9.
"designed to serve" the city's substantial interest in
reducing crime. The challenged ordinance was
After a city building inspector found in 1995 that therefore invalid under Renton, 475 U.S. 41. 222 F.3d
Alameda gooks, Inc., was operating both as an adult at 723 -724. We granted certiorari, 532 U.S. 902
bookstore and an adult arcade in violation of the city's (2001), to clarify the standard for determining whether
adult zoning regulations, respondents joined as an ordinance serves a substantial government interest
plaintiffs and sued under 42 U.S.C. § 1983 for under Renton, supra.
declaratory and injunctive relief to prevent II
enforcement of the ordinance. 222 F.3d at 721. At
issue in this case is count I of the complaint, which In Renton v. Playtime Theatres, Inc., supra, this
alleges a facial violation of the First Amendment. Both Court considered the validity of a municipal ordinance
the city and respondents filed crossmotions for that prohibited any adult movie theater from locating
summary judgment. within 1,000 feet of any residential zone, family
dwelling, church, park, or school. Our analysis of the
ordinance proceeded in three steps. First, we found that
7
the ordinance did not ban adult theaters altogether, but upheld a North Carolina statute similar to the Los
merely required that they be distanced from certain Angeles ordinance challenged in this case. 612 F.2d
sensitive locations. The ordinance was properly 821.
analyzed, therefore, as a time, place, and manner The central of the 1977 study component
regulation. Id at 46. We next considered whether the p y is a report on
ordinance was content { * *18} neutral or content city crime patterns provided by the Los Angeles Police
based. If the regulation were content based, it would be Department. That report indicated that, during the
considered presumptively invalid and subject to strict period from 1965 to 1975, certain crime rates grew
scrutiny. Simon & Schuster, Inc. v. Members of N. Y. much faster in Hollywood, which had the largest
State Crime Victims Bd., 502 U.S. 105, 115, 118, 116 concentration of adult establishments in the city, than
L. Ed. 2d 476, 112 S. Ct. 501 (1991); Arkansas in the city of Los Angeles as a whole. For example,
Writers' Project, Inc. v. Ragland, 481 U.S. 221, 230- robberies increased 3 times faster and prostitution 15
231, 95 L. Ed. 2d 209, 107 S. Ct. 1722 (1987). We times faster in Hollywood than citywide. App. 124
held, however, that the Renton ordinance was aimed 125.
not at the content of the films shown at adult theaters, The 1977 study also contains reports conducted
but rather at the secondary effects of such theaters on directly by the staff of the Los Angeles Planning
the surrounding community, namely at crime rates, Department that examine the relationship between
property values, and the quality of the city's adult establishments and property values. These staff
neighborhoods. Therefore, the ordinance was deemed reports, however, are inconclusive. Not surprisingly,
content neutral. Renton, supra, at 47-49. Finally, the parties focus their dispute before this Court on the
given this finding, we stated that the ordinance would report by the Los Angeles Police Department. { * *21 }
be upheld so long as the city of Renton showed that its Because we find that reducing crime is a substantial
ordinance was designed to serve a substantial govemment interest and that the police department
government interest and that reasonable alternative report's conclusions regarding crime patterns may
avenues of communication remained available. 475 reasonably be relied upon to overcome summary
U.S. at 50. We concluded that Renton had met this judgment against the city, we also focus on the portion
burden, and we upheld its ordinance. Id., at 51 -54. of the 1977 study drawn from the police department
The Court of Appeals applied the same analysis to report.
evaluate the Los Angeles ordinance { * *19} The Court of Appeals found that the 1977 study did
challenged in this case. First, the Court of Appeals not reasonably support the inference that a
found that the Los Angeles ordinance was not a concentration of adult operations within a single adult
complete ban on adult entertainment establishments, establishment produced greater levels of criminal
but rather a sort of adult zoning regulation, which activity because the study focused on the effect that a
Renton considered a time, place, and manner concentration of establishments —not a concentration of
regulation. 222 F.3d at 723. The Court of Appeals operations within a single establishment- -had on crime
turned to the second step of the Renton analysis, but rates. The Court of Appeals pointed out that the study
did not draw any conclusions about whether the Los treated combination adult bookstore /arcades as single
Angeles ordinance was content based. It explained establishments and did not study the effect of any
that, even if the Los Angeles ordinance were content separate - standing adult bookstore or arcade. 222 F.3d
neutral, the city had failed to demonstrate, as required at 724.
by the third step of the Renton analysis, that its
prohibition on multiple -use adult establishments was The Court of Appeals misunderstood the implications
designed to serve its substantial interest in reducing of the 1977 study. While the study reveals that areas
crime. The Court of Appeals noted that the primary with high concentrations of adult establishments are
evidence relied upon by Los Angeles to demonstrate a associated with high crime rates, areas with high
link between combination adult businesses and harmful concentrations of adult establishments are also areas
secondary effects was the 1977 study conducted by the with high concentrations { * *22} of adult operations,
city's planning department. The Court of Appeals albeit each in separate establishments. It was therefore
consistent with the
found, however, that the city could not rely on that findings of the 1977 study, and thus
study because it did not "'support a reasonable belief reasonable, for Los Angeles to suppose that a
that [the] combination [of] businesses ... produced concentration of adult establishments is correlated with
harmful secondary effects { * *20} of the type high crime rates because a concentration of operations
asserted." 222 F.3d at 724. For similar reasons, the in one locale draws, for example, a greater
Court of Appeals also rejected the city's attempt to rely concentration of adult consumers to the neighborhood,
on a report on health conditions inside adult video and a high density of such consumers either attracts or
arcades described in Hart Book Stores, a case that generates criminal activity. The assumption behind this
theory is that having a number of adult operations in
one single adult establishment draws the same dense Respondents make the same logical error as the Court
foot traffic as having a number of distinct adult of Appeals when they suggest that the city's prohibition
establishments in close proximity, much as minimalls on multiuse establishments will raise crime rates in
and department stores similarly attract the crowds of certain neighborhoods because it will force certain
consumers. Brief for Petitioner 28. Under this view, it adult businesses to relocate to areas without any other
is rational for the city to infer that reducing the adult businesses. Respondents' claim assumes that the
concentration of adult operations in a neighborhood, 1977 study proves that all adult businesses, whether or
whether within separate establishments or in one large not they are located near other adult businesses,
establishment, will reduce crime rates. generate crime. { * *25} This is a plausible reading of
Neither the Court of Appeals, nor respondents, nor the the results from the 1977 study, but respondents do not
dissent provides any reason to question the city's demonstrate that it is a compelled reading. Nor do they
theory. In particular, they do not offer a competing provide evidence that refutes the city's interpretation of
theory, let alone { * *23} data, that explains why the the study, under which the city's prohibition should on
elevated crime rates in neighborhoods with a balance reduce crime. If this Court were nevertheless
concentration of adult establishments can be attributed to accept respondents' speculation, it would effectively
entirely to the presence of permanent walls between, require that the city provide evidence that not only
and separate entrances to, each individual adult _supports the claim that its ordinance serves an
operation. While the city certainly bears the burden of important government interest, but also does not
providing evidence that supports a link between provide support for any other approach to serve that
concentrations of adult operations and asserted interest.
secondary effects, it does not bear the burden of In Renton, we specifically refused to set such a high
providing evidence that rules out every theory for the bar for municipalities that want to address merely the
link between concentrations of adult establishments secondary effects of protected speech. We held that a
that is inconsistent with its own. municipality may rely on any evidence that is
The error that the Court of Appeals made is that it "reasonably believed to be relevant" for demonstrating
required the city to prove that its theory about a a connection between speech and a substantial,
concentration of adult operations attracting crowds of independent government interest. 475 U.S. at 51 -52;
customers, much like a minimall or department store see also, e.g., Barnes v. Glen Theatre, Inc., 501 U.S.
does, is a necessary consequence of the 1977 study. 560, 584, 115 L. Ed. 2d 504, 111 S. Ct. 2456 (1991)
For example, the Court of Appeals refused to allow the (SOUTER, J., concurring in judgment) (permitting
city to draw the inference that "the expansion of an municipality to use evidence that adult theaters are
adult bookstore to include an adult arcade would correlated with harmful secondary effects { * *26} to
increase" business activity and "produce the harmful support its claim that nude dancing is likely to produce
secondary effects identified in the Study." 222 F.3d at the same effects). This is not to say that a municipality
726. It reasoned that such an inference would justify can get away with shoddy data or reasoning. The
limits on the inventory of an { * *24} adult bookstore, municipality's evidence must fairly support the
not a ban on the combination of an adult bookstore and municipality's rationale for its ordinance. If plaintiffs
an adult arcade. The Court of Appeals simply replaced fail to cast direct doubt on this rationale, either by
the city's theory—that having many different operations demonstrating that the municipality's evidence does not
in close Rroximity attracts crowds —with its own -that support its rationale or by furnishing evidence that
the size of an operation attracts crowds. If the Court of disputes the municipality's factual findings, the
Appeals' theory is correct, then inventory limits make municipality meets the standard set forth in Renton. If
more sense. If the city's theory is correct, then a plaintiffs succeed in casting doubt on a municipality's
prohibition on the combination of businesses makes rationale in either manner, the burden shifts back to the
more sense. Both theories are consistent with the data municipality to supplement the record with evidence
in the 1977 study. The Court of Appeals' analysis, renewing support for a theory that justifies its
however, implicitly requires the city to prove that its ordinance. See, e.g., Erie v. Pap's A. M., 529 U.S.
theory is the only one that can plausibly explain the 277, 298, 146 L. Ed. 2d 265, 120 S. Ct. 1382 (2000)
data because only in this manner can the city refute the (plurality opinion). This case is at a very early stage in
Court of Appeals' logic. this process. It arrives on a summary judgment motion
by respondents defended only by complaints that the
9
1977 study fails to prove that the city's justification for 666; Erie v. Pap's A. M., supra, at 297 -298 (plurality
its ordinance is necessarily correct. Therefore, we opinion). We are also guided by the fact that Renton
conclude that the city, at this stage of the litigation, has requires that municipal ordinances receive only
complied { * *27} with the evidentiary requirement in intermediate scrutiny if they are content neutral.
Renton. Renton, supra, at 48 -50. There is less reason to be
JUSTICE SOUTER faults the city for relying on the concerned that municipalities will use these ordinances
1977 study not because the study fails to support the to discriminate against unpopular speech. See. Erie,
city's theory that adult department stores, like adult supra, at 298 -299.
minimalls, attract customers and thus crime, but JUSTICE SOUTER would have us rethink this
because the city does not demonstrate that free- balance, and indeed the entire Renton framework. In
standing single -use adult establishments reduce crime. Renton, the Court distinguished the inquiry into
See post, at 8 -9 (dissenting opinion). In effect, whether a municipal ordinance is content neutral from
JUSTICE SOUTER asks the city to demonstrate, not the inquiry into whether it is "designed to serve a
merely by appeal to common sense, but also with substantial government interest and do not
empirical data, that its ordinance will successfully unreasonably limit alternative avenues of
lower crime. Our cases have never required that communication." 475 U.S. at 47 -54. The former
municipalities make such a showing, certainly not requires courts to verify that the "predominate
without actual and convincing evidence from plaintiffs concerns" motivating the ordinance "were with the
to the contrary. See, e.g., Barnes, supra, at 583 -584 secondary effects of adult [speech], and not with the
( SOUTER, J., concurring in judgment). Such a content { * *30} of adult [speech]." Id., at 47. The
requirement would go too far in undermining our latter inquiry goes one step further and asks whether
settled position that municipalities must be given a the municipality can demonstrate a connection between
"reasonable opportunity to experiment with solutions "' the speech regulated by the ordinance and the
to address the secondary effects of protected speech. secondary effects that motivated the adoption of the
Renton, supra, at 52 (quoting Young v. American ordinance. Only at this stage did Renton contemplate
Mini Theatres, Inc., 427 U.S. 50, 71, 49 L. Ed. 2d that courts would examine evidence concerning
310, 96 S. Ct. 2440 (1976) (plurality opinion)). A regulated speech and secondary effects. Id., at 50 -52.
municipality considering { * *28} an innovative JUSTICE SOUTER would either merge these two
solution may not have data that could demonstrate the inquiries or move the evidentiary analysis into the
efficacy of its proposal because the solution would, by inquiry on content neutrality, and raise the evidentiary
definition, not have been implemented previously. The bar that a municipality must pass. His logic is that
city's ordinance banning multiple -use adult verifying that the ordinance actually reduces the
establishments is such a solution. Respondents contend secondary effects asserted would ensure that zoning
that there are no adult video arcades in Los Angeles regulations are not merely content -based regulations in
County that operate independently of adult bookstores. disguise. See post, at 5 -6.
See Brief for Respondents 41. But without such
arcades, the city does not have a treatment group to We this proposal unwise. First, none of the
compare with the control group of multiple -use adult parties request the Court to depart from the Renton
establishments, and without such a comparison framework. Nor is the proposal fairly encompassed in
JUSTICE SOUTER would strike down the city's the question presented, which focuses on the sorts of
ordinance, This leaves the city with no means to evidence upon which the city may rely to demonstrate
address the secondary effects with which it is that its ordinance is designed to serve a substantial
concerned. governmental interest. Pet. for Cert. i. Second, {**31)
there is no evidence suggesting that courts have
Our deference to the evidence presented by the city of difficulty determining whether municipal ordinances
Los Angeles is the product of a careful balance are motivated primarily by the content of adult speech
between competing interests. One the one hand, we or by its secondary effects without looking to evidence
have an "obligation to exercise independent judgment connecting such speech to the asserted secondary
when First Amendment rights are implicated." Turner effects. In this case, the Court of Appeals has not yet
Broadcasting System, Inc. v. FCC, 512 U.S. 622, 666, had an opportunity to address the issue, having
129 L. Ed. 2d 497, 114 S. Ct. 2445 (1994) (plurality assumed for the sake of argument that the city's
opinion); see also Landmark Communications, Inc. v. ordinance is content neutral. 222 F.3d at 723. It would
Virginia, 435 U.S. 829, 843 -844, 56 L. Ed. 2d 1, 98 S. be inappropriate for this Court to reach the question of
Ct. 1535 (1978). On { * *29} the other hand, we must content neutrality before permitting the lower court to
acknowledge that the Los Angeles City Council is in a pass upon it. Finally, JUSTICE SOUTER does not
better position than the Judiciary to gather and evaluate clarify the sort of evidence upon which municipalities
data on local problems. See Turner, supra, at 665- may rely to meet the evidentiary burden he would
require. It is easy to say that courts must demand regulation, and that the Court subject the ordinance to
evidence when "common experiences" or "common strict scrutiny. This also appears to be the theme of
assumptions" are incorrect, see post, at 6 -7, but it is JUSTICE KENNEDY'S concurrence. He contends that
difficult for courts to know ahead of time whether that "[a] city may not assert that it will reduce secondary
condition is met. Municipalities will, in general, have effects by reducing speech in the same proportion."
greater experience with and understanding of the Post, at 7 (opinion concurring in judgment). We
secondary effects that follow certain protected speech consider that unobjectionable { * *34} proposition as
than will the courts. See Pap's A. M., 529 U.S. at 297- simply a reformulation of the requirement that an
298 (plurality { * *32} opinion). For this reason our ordinance warrants intermediate scrutiny only if it is a
cases require only that municipalities rely upon time, place, and manner regulation and not a ban. The
evidence that is "reasonably believed to be relevant" to Court of Appeals held, however, that the city's
the secondary effects that they seek to address. prohibition on the combination of adult bookstores and
IB arcades is not a ban and respondents did not petition
for review of that determination.
The city of Los Angeles argues that its prohibition on Accordingly, we reverse the Court of Appeals'
multiuse establishments draws further support from a judgment granting summary judgment to respondents
study of the poor health conditions in adult video and remand the case for further proceedings.
arcades described in Hart Book Stores, a case that
upheld a North Carolina ordinance similar to that It is so ordered.
challenged here. See 612 F.2d at 828, n. 9. CONCURBY: SCALIA; KENNEDY
Respondents argue that the city cannot rely on
evidence from Hart Book Stores because the city CONCUR: JUSTICE SCALIA, concurring.
cannot prove it examined that evidence before it
enacted the current version of § 12.70(C). Brief for I join the plurality opinion because I think it represents
a correct application of our jurisprudence concerning
Respondents 21. Respondents note, moreover, that regulation of the "secondary effects" of pornographic
unsanitary conditions in adult video arcades would speech. As I have said elsewhere, however, in a case
persist regardless of whether arcades were operated in such as this our First Amendment traditions make
the same buildings as, say, adult bookstores. Ibid. "secondary effects" analysis quite unnecessary. The
We do not, however, need to resolve the parties' Constitution does not prevent those communities that
dispute over evidence cited in Hart Book Stores. wish to do so from regulating, or indeed entirely
Unlike the city of Renton, the city of Los Angeles suppressing, the business of pandering sex. See, e.g.,
conducted its own study of adult businesses. We have Erie v. Pap's A. M., 529 U.S. 277, 310, 146 L. Ed. 2d
concluded that the Los Angeles study provides 265, 120 S. Ct. 1382 (2000) (SCALIA, J., concurring
evidence to support the { * *33} city's theory that a in judgment); FW/PBS, Inc. v. Dallas, 493 U.S. 215,
concentration of adult operations in one locale attracts 256 -261, 107 L. Ed. 2d 603, 110 S. Ct. 596 (1990)
crime, and can be reasonably relied upon to { * *35} (SCALIA, J., concurring in part and dissenting
demonstrate that Los Angeles Municipal Code § in part).
12.70(C) (1983) is designed to promote the city's JUSTICE KENNEDY, concurring in the judgment.
interest in reducing crime. Therefore; the city need not
present foreign studies to overcome the summary Speech can produce tangible consequences: It can
judgment.against it. change minds. It can prompt actions. These primary
Before concluding, it should be noted that respondents effects signify the power and the necessity of free
argue, as an alternative basis to sustain the Court of speech. Speech can also cause secondary effects,
Appeals' judgment, that the Los Angeles ordinance is however, unrelated to the impact of the speech on its
not a typical zoning regulation. Rather, respondents audience. A newspaper factory may cause pollution,
explain, the prohibition on multiuse adult and a billboard may obstruct a view. These secondary
establishments is effectively a ban on adult video consequences are not always immune from regulation
arcades because no such business exists independently by zoning laws even though they are produced by
of an adult bookstore. Brief for Respondents 12 -13. speech.
Respondents request that the Court hold that the Los Municipal governments know that high concentrations
Angeles ordinance is not a time, place, and manner of adult businesses can damage the value and the
11
integrity of a neighborhood. The damage is inexorable that a city could reduce secondary effects
measurable; it is all too real. The law does not require a by reducing speech, this is not a permissible strategy.
city to ignore these consequences if it uses its zoning The purpose and effect of a zoning ordinance must be
power in a reasonable way to ameliorate them without to reduce secondary effects and not to reduce speech.
suppressing. speech. A city's "interest in attempting to
preserve the quality of urban life is one that must be A zoning measure can be consistent with the First
accorded high respect." Young v. American Mini Amendment if it is likely to cause a significant
Theatres, Inc., 427 U.S. 50, 71, 49 L. Ed. 2d 310, 96 decrease { * *38} in secondary effects and a trivial
S. Ct. 2440 (1976) (plurality opinion). decrease in the quantity of speech. It is well
documented that multiple adult businesses in close
The question in this case is whether Los Angeles can proximity may change the character of a neighborhood
seek to reduce these tangible, { * *36} adverse for the worse. Those same businesses spread across the
consequences by separating adult speech businesses city may not have the same deleterious effects. At least
from one another- -even two businesses that have in theory, a dispersal ordinance causes these businesses
always been under the same roof. In my view our to separate rather than to close, so negative
precedents may allow the city to impose its regulation externalities are diminished but speech is not.
in the exercise of the zoning impose its regulation in
the exercise of the zoning authority. The city is not, at The calculus is a familiar one to city planners, for
least, to be foreclosed by summary judgment, so I many enterprises other than adult businesses also cause
concur in the judgment. undesirable externalities. Factories, for example, may
cause pollution, so a city may seek to reduce the cost
This separate statement seems to me necessary, of that externality by restricting factories to areas far
however, for two reasons. First, Renton v. Playtime from residential neighborhoods. With careful urban
Theatres, Inc., 475 U.S. 41, 89 L. Ed. 2d 29, 106 S. planning a city in this way may reduce the costs of
Ct. 925 (1986), described a similar ordinance as pollution for communities, while at the same time
"content neutral," and I agree with the dissent that the allowing the productive work of the factories to
designation is imprecise. Second, in my view, the continue. The challenge is to protect the. activity inside
plurality's application of Renton might constitute a while controlling side effects outside.
subtle expansion, with which I do not concur.
Such an ordinance might, like a speech restriction, be
I "content based." It might, for example, single out
In Renton, the Court determined that while the slaughterhouses for specific zoning treatment,
material inside adult bookstores and movie theaters is restricting them to { * *39} a particularly remote part of
speech, the consequent sordidness outside is not. The town. Without knowing more, however, one would
challenge is to correct the latter while leaving the hardly presume that because the ordinance is specific
former, as far as possible, untouched. If a city can to that business, the city seeks to discriminate against it
decrease the crime and blight associated with certain or help a favored group. One would presume, rather,
speech by the traditional exercise of its zoning power, that the ordinance targets not the business but its
Particular noxious side effects. But. cf. Slaug /rter
and at the same time leave the quantity and
accessibility of the speech substantially { * *37} House Cases, 83 U.S. 36, 16 Wall. 36, 21 L. Ed. 394
undiminished, there is no First Amendment objection. (1873). The business might well be the city's most
This is so even if the measure identifies the problem valued enterprise; nevertheless, because of the
outside by reference to the speech inside —that is, even pollution it causes, it may warrant special zoning
treatment. This sort of singling out is not impermissible
if the measure is in that sense content based.
content discrimination; it is sensible urban planning.
On the other hand, a city may not regulate the Cf. Village of Euclid v. Ambler Realty Co., 272 U.S.
secondary effects of speech by suppressing the speech 365, 388, 71 L. Ed. 303, 47 S. Ct. 114 (1926) ( "A
itself. A city may not, for example, impose a content- nuisance may be merely a right thing in the wrong
based fee or tax. See Arkansas Writers' Project, Inc. place, - -like a pig in the parlor instead of the barnyard.
v. Ragland, 481 U.S. 221, 230, 95 L. Ed. 2d 209, 107 If the validity of the legislative classification for
S. Ct. 1722 (1987) ("Official scrutiny of the content of zoning purposes be fairly debatable, the legislative
publications as the basis for imposing a tax is entirely judgment must be allowed to control ").
incompatible with the First Amendment's guarantee of
freedom of the press "). This is true even if the True, the First Amendment protects speech and not
government purports to justify the fee by reference to slaughterhouses. But in both contexts, the inference of
secondary effects. See Forsyth County v. Nationalist impermissible discrimination is not- strong. An equally
Movement, 505 U.S. 123, 134 - 135, 120 L. Ed. 2d 101, - strong inference is that the ordinance { * *40} is
112 S. Ct. 2395 (1992). Though the inference may be targeted not at the activity, but at its side effects. If a
zoning ordinance is directed to the secondary effects of
adult speech, the ordinance does not necessarily the statute describes speech by content then it is
constitute impermissible content discrimination. A content based. And the ordinance in Renton "treat[ed]
zoning law need not be blind to the secondary effects theaters that specialize in adult films differently from
of adult speech, so long as the purpose of the law is not other kinds of theaters." Id, at 47. The fiction that this
to suppress it. sort of ordinance is content neutral - -or "content
The ordinance at issue in this case is not limited to neutral " - -is perhaps more confusing than helpful, as
expressive activities. It also extends, for example, to JUSTICE SOUTER demonstrates, see post, at 4
massage parlors, which the city has found to cause (dissenting opinion). It is also not a fiction that has
similar secondary effects. See Los Angeles Municipal commanded our consistent adherence. See Thomas v.
Code §§ 12.70(B)(8) (1978), 12.70(B)(17) (1983), Chicago Park Dist., 534 U.S. 316, 322, 151 L. Ed. 2d
1270 C 783, 122 S. Ct. 775, and n. 2 (2002) (suggesting that a
( ) (1986), as amended. This ordinance, licensing scheme targeting only those businesses
moreover, is just one part of an elaborate web of land -
use regulations in Los Angeles, all of which are purveying sexually explicit speech is not content
intended to promote the social value of the land as a neutral). These ordinances are content based and we
whole without suppressing some activities or favoring should call them so.
others. See § 12.02 ( "The purpose of this article is to Nevertheless, for the reasons discussed above, the
consolidate and coordinate all existing zoning central holding of Renton is sound: A zoning
regulations and provisions into one comprehensive restriction that is designed to decrease secondary
zoning plan . . . in order to encourage the most effects and not speech should be subject to
appropriate use of land ... and to promote the health, intermediate rather than strict {**43 } scrutiny.
safety, and the general welfare ... "). All this further Generally, the government has no power to restrict
suggests that {**411 the ordinance is more in the speech based on content, but there are exceptions to the
nature of a typical land -use restriction and less in the rule. See Simon & Schuster, Inc. v. Members of N. Y.
nature of a law suppressing speech. State Crime Victims Bd., 502 U.S. 105, 126 -127, 116
For these reasons, the ordinance is not so suspect that L. Ed. 2d 476, 112 S. Ct. 501 (1991) (KENNEDY, J.,
we must employ the usual rigorous analysis that concurring in judgment). And zoning regulations do
content based laws demand in other instances. The not automatically raise the specter of impermissible
ordinance may be a covert attack on speech, but we content discrimination, even if they are content based,
should not presume it to be so. In the language of our because they have a prima facie legitimate purpose: to
First Amendment doctrine it calls for intermediate and limit the negative externalities of land use. As a matter
of common experience, these sorts of ordinances are
not strict scrutiny, as we held in Renton.
more like a zoning restriction on slaughterhouses and
II less like a tax on unpopular newspapers. The zoning
In Renton, the Court began by noting that a zoning context provides a built-in legitimate rationale, which
ordinance is a time, place, or manner restriction. The rebuts the usual presumption that content -based
Court then proceeded to consider the question whether restrictions are unconstitutional. For this reason, we
the ordinance was "content based." The ordinance "by apply intermediate rather than strict scrutiny.
its terms [was] designed to prevent crime, protect the III
city's retail trade, maintain property values, and
generally,protect and preserve the quality of [the city's] The narrow question presented in this case is whether
neighborhoods, commercial districts, and the quality of the ordinance at issue is invalid "because the city did
urban life, not to suppress the expression of unpopular not study the negative effects of such combinations of
views." 475 U.S. at 48 (internal quotation marks adult businesses, but rather relied on judicially
omitted). On this premise, the Court designated the approved statutory precedent from other jurisdictions."
restriction "content neutral." Ibid. Pet. for Cert. i. This question { * *44} is actually two
questions. First, what proposition does a city need to
The Court appeared to recognize, however, that the advance in order to sustain a secondary- effects
designation { * *42} was something of a fiction, which, ordinance? Second, how much evidence is required to
perhaps, is why it kept the phrase in quotes. After all, support the proposition? The plurality skips to the
whether a statute is content neutral or content based is second question and gives the correct answer; but in
something that can be determined on the face of it; if my view more attention must be given to the first.
13
At the outset, we must identify the claim a city must One business will either move elsewhere or close. The
make in order to justify a content -based zoning city's premise cannot be the latter. It is true that cutting
ordinance. As discussed above, a city must advance adult speech in half would probably reduce secondary
some basis to show that its regulation has the purpose effects proportionately. But again, a promised
Proportional reduction does not suffice. Content -based
and effect of suppressing secondary effects, while
leaving the quantity and accessibility of speech taxes could achieve that, yet these are impermissible.
substantially intact. The ordinance may identify the The premise, therefore, must be that businesses - -even
speech based on content, but only as a shorthand for those that have always been under one roof- -will for
identifying the secondary effects outside. A city may the most part disperse rather than shut down. True, this
not assert that it will reduce secondary effects by premise { * *47} has its own conundrum. As JUSTICE
reducing speech in the same proportion. On this point, SOUTER writes, "the city... claims no interest in the
I agree with JUSTICE SOUTER. See post, at 5. The proliferation of adult businesses." Post, at 9. The claim,
rationale of the ordinance must be that it will suppress therefore, must be that this ordinance will cause two
secondary effects- -and not by suppressing speech. businesses to split rather than one to close, that the
quantity of speech will be substantially undiminished,
The plurality's statement of the proposition to be
supported is somewhat different. It suggests that Los and that total secondary effects will be significantly
Angeles could reason as follows: { * *45} (1) "a reduced. This must be the rationale of a dispersal
concentration of operations in one locale draws ... a statute.
greater concentration of adult consumers to the Only after identifying the proposition to be proved can
neighborhood, and a high density of such consumers we ask the second part of the question presented: is
either attracts or generates criminal activity"; (2) there sufficient evidence to support the proposition? As
"having a number of adult operations in one single to this, we have consistently held that a city must have
adult establishment draws the same dense foot traffic latitude to experiment, at least at the outset, and that
as having a number of distinct adult establishments in very little evidence is required. See, e.g., Renton, 475
close proximity"; (3) "reducing the concentration of U.S. at 51 -52 ( "The First Amendment does not require
adult operations in a neighborhood, whether within a city, before enacting such an ordinance, to conduct
separate establishments or in one large establishment, new studies or produce evidence independent of that
will reduce crime rates." Ante, at 8 -9. already generated by other cities, so long as whatever
These propositions all seem reasonable, and the evidence the city relies upon is reasonably believed to
inferences required to get from one to the next are be relevant to the problem that the city addresses ");
sensible. Nevertheless, this syllogism fails to capture Young, 427 U.S. at 71 ( "The city must be allowed a
an important part of the inquiry. The plurality's reasonable opportunity { * *48} to experiment with
analysis does not address how speech will fare under solutions to admittedly serious problems "); Erie v.
the city's ordinance. As discussed, the necessary
Pap's A. M., 529 U.S. 277, 300 -301, 146 L. Ed. 2d
rationale for applying intermediate scrutiny is the 265, 120 S. Ct. 1382 (2000) (plurality opinion). As a
promise that zoning ordinances like this one may general matter, courts should not be in the business of
reduce the costs of secondary effects without second - guessing fact -bound empirical assessments of
substantially reducing speech. For this reason, it does city planners. See Renton, supra, at 51 -52. The Los
not suffice to say that inconvenience will reduce Angeles City Council knows the streets of Los Angeles
demand and fewer patrons will lead to fewer secondary better than we do. See Turner Broadcasting System,
effects. {' *46} This reasoning would as easily justify Inc. v. FCC, 512 U.S. 622, 665 -666, 129 L. Ed. 2d
a content -based tax: Increased prices will reduce 497, 114 S. Ct. 2445 (1994); Erie, supra, at 297 -298
demand, and fewer customers will mean fewer (plurality opinion). It is entitled to rely on that
secondary effects. But a content -based tax may not be knowledge; and if its inferences appear reasonable, we
justified in this manner. See Arkansas Writers' should not say there is no basis for its conclusion.
Project, Inc. v. Ragland, 481 U.S. 221, 95 L. Ed. 2d In this case the proposition to be shown is supported
209, 107 S. Ct. 1722 (1987); Forsyth County v. by a single study and common experience. The city's
Nationalist Movement, 505 U.S. 123, 120 L. Ed. 2d study shows a correlation between the concentration of
101, 112 S. Ct. 2395 (1992). It is no trick to reduce adult establishments and crime. Two or more adult
secondary effects by reducing speech or its audience; businesses in close proximity seem to attract a critical
but a city may not attack secondary effects indirectly mass of unsavory characters and the crime rate may
by attacking speech. increase as a result. The city, therefore, sought to
The analysis requires a few more steps. If two adult disperse these businesses. Los Angeles Municipal
businesses are under the same roof, an ordinance Code § 12.70(C) (1983), as amended. This original
requiring them to separate will have one of two results:
ordinance is not challenged { * *49} here, and we may DISSENT: JUSTICE SOUTER, with whom JUSTICE
assume that it is constitutional. STEVENS and JUSTICE GINSBURG { * *51 } join,
If we assume that the study supports the original and with whom JUSTICE BREYER joins as to Part II,
ordinance, then most of the necessary analysis follows. dissenting.
We may posit that two adult stores next door to each In 1977, the city of Los Angeles studied sections of
other attract 100 patrons per day. The two businesses the city with high and low concentrations of adult
split apart might attract 49 patrons each. (Two patrons,
perhaps, will be discouraged by the inconvenience of business establishments catering to the market for the
the separation - -a relatively small cost to speech.) On erotic. The city found no certain correlation between
the other hand, the reduction in secondary effects the location of those establishments and depressed
Property values, but it did
might be dramatic, because secondary effects may find some correlation
require a critical mass. Depending on the economics of between areas of higher concentrations of such
vice, 100 potential customers /victims might attract a business and higher crime rates. On that basis, Los
coterie of thieves, prostitutes, and other ne'er -do- wells; Angeles followed the examples of other cities in
yet 49 might attract none at all. If so, a dispersal adopting a zoning ordinance requiring dispersion of
ordinance would cause a great reduction in secondary adult establishments. Iassume that the ordinance was
effects at very small cost to speech. Indeed, the very constitutional when adopted, see, e.g., Young v.
absence of secondary effects might increase the American Mini Theatres, Inc., 427 U.S. 50, 49 L. Ed.
audience for the speech; perhaps for every two people 2d 310, 96 S. Ct. 2440 (1976), and assume for
who are discouraged by the inconvenience of two -stop purposes of this case that the original ordinance
shopping, another two are encouraged by hospitable remains valid today. nl
surroundings. In that case, secondary effects might be
eliminated at no cost to speech whatsoever, and both Footnotes
the city and the speaker { * *50} will have their
interests well served. n1 Although amicus First Amendment
Only one small step remains to justify the ordinance at Lawyers Association argues that recent
issue in this case. The city may next infer —from its studies refute the findings of adult business
study and from its own experience —that two adult correlations with secondary effects
businesses under the same roof are no better than two sufficient to justify such an ordinance,
next door. The city could reach the reasonable Brief for First Amendment Lawyers
conclusion that knocking down the wall between two Association as Amicus Curiae 21 -23, the
adult businesses does not ameliorate any undesirable issue is one I do not reach.
secondary effects of their proximity to one another. If
the city's first ordinance was justified, therefore, then
- - -End Footnotes- - -
the second is too. Dispersing two adult businesses { * *52}
under one roof is reasonably likely to cause a
substantial reduction in secondary effects while The city subsequently amended its ordinance to forbid
reducing speech very little. clusters of such businesses at one address, as in a mall.
IV The city has, in turn, taken a third step to apply this
amendment to prohibit even a single proprietor from
These propositions are well established in common doing business in a traditional way that combines an
experience and in zoning policies that we have already adult bookstore, selling books, magazines, and videos,
examined, and for these reasons this ordinance is not with an adult arcade, consisting of open viewing
invalid on its face. If these assumptions can be proved booths, where potential purchasers of videos can view
unsound at trial, then the ordinance might not them for a fee.
withstand intermediate scrutiny. The ordinance does, From a policy of dispersing adult establishments, the
however, survive the summary judgment motion that
the Court of Appeals ordered granted in this case. city has thus moved to a policy of dividing them in
two. The justification claimed for this application of
DISSENTBY: SOUTER the new policy remains, however, the 1977 survey, as
supplemented by the authority of one decided case on
15
regulating adult arcades in another State. The case wrong with a loudspeaker at three in the morning, see
authority is not on point, see infra, at 9, n. 4, and the Kovacs v. Cooper, 336 U.S. 77, 93 L. Ed. 513, 69 S.
1977 survey provides no support for the breakup Ct. 448 (1949); the sentiment may not provoke, but
policy. Its evidentiary insufficiency bears emphasis and being blasted out of a sound sleep { * *55} does. In
is the principal reason that I respectfully dissent from such a case, we ask simply whether the regulation is
the Court's judgment today. narrowly tailored to serve a significant governmental
I interest, and . . . leave[s] open ample alternative
channels for communication of the information." Clark
This ordinance stands or falls on the results of what v. Community for Creative Non - Violence, 468 U.S.
our cases speak of as intermediate scrutiny, generally 288, 293, 82 L. Ed. 2d 221, 104 S. Ct. 3065 (1984). A
contrasted with the demanding standard applied under middle -tier standard is also applied to limits on
the First Amendment { * *53} to a content -based expression through action that is otherwise subject to
regulation of expression. The variants of middle -tier regulation for nonexpressive purposes, the best known
tests cover a grab -bag of restrictive, statutes, with a example being the prohibition on destroying draft cards
corresponding variety of justifications. While spoken as an act of protest, United States v. O'Brien, 391 U.S.
of as content neutral, these regulations are not 367, 20 L. Ed. 2d 672, 88 S. Ct. 1673 (1968); here a
uniformly distinct from the content -based regulations regulation passes muster "if it furthers an important or
calling for scrutiny that is strict, and zoning of substantial governmental interest ... unrelated to the
businesses based on their sales of expressive adult suppression of free expression" by a restriction "no
material receives mid -level scrutiny, even though it greater than is essential to the furtherance of that
raises a risk of content -based restriction. It is worth interest." Id., at 377. As mentioned already, yet
being clear, then, on how close to a content basis adult another middle -tier variety is zoning restriction as a
business zoning can get, and why the application of a means of responding to the "secondary effects" of adult
middle -tier standard to zoning regulation of adult businesses, principally crime and declining property
bookstores calls for particular care. values in the neighborhood. Renton v. Playtime
Because content -based regulation applies to Theatres, Inc., 475 U.S. 41, 49, 89 L. Ed. 2d 29, 106
expression by very reason of what is said, it carries a S. Ct. 925 (1986). n2
high risk that expressive limits are imposed for the
sake of suppressing a message that is disagreeable to Footnotes
listeners or readers, or the government. See
Consolidated Edison Co. of N. Y. v. Public Serv.
n2
Comm'n of N. Y., 447 U.S. 530, 536, 65 L. Ed. 2d Limiting such effects qualifies as a
319, 100 S. Ct. 2326 (1980) ( "When regulation is substantial governmental interest, and an
based on the content of speech, governmental action ordinance has been said to survive if it is
must be scrutinized more carefully to ensure that shown to serve such ends without
communication * *54 has not been unreasonably limiting alternatives.
{ } prohibited Renton, 475 U.S. at 50. Because Renton
merely because public officials disapprove the
speaker's views" (internal quotation marks omitted)). A called its secondary- effects ordinance a
restriction based on content survives only on a showing mere time, place, or manner restriction and
of necessity to serve a legitimate and compelling thereby glossed over the role of content in
governmental interest, combined with least- restrictive secondary- effects zoning, see infra this
narrow tailoring to serve it, see United States v. page, I believe the soft focus of its
Playboy Entertainment Group, Inc., 529 U.S. 803, statement of the middle -tier test should be
813, 146 L. Ed. 2d 865, 120 S. Ct. 1878 (2000); since rejected in favor of the United States v.
merely protecting listeners from offense at the message O'Brien, 391 U.S. 367, 20 L. Ed. 2d 672,
is not a legitimate interest of the government, see 88 S. Ct. 1673 (1968), formulation quoted
Cohen v. California, 403 U.S. 15, 24 -25, 29 L. Ed. 2d above. O'Brien is a closer relative of
284, 91 S. Ct. 1780 (1971), strict scrutiny leaves few secondary- effects zoning than mere time,
survivors. place, or manner regulations, as the Court
has implicitly recognized. Erie v. Pap's A.
The comparatively softer intermediate scrutiny is M., 529 U.S. 277, 289, 146 L. Ed. 2d 265,
reserved for regulations justified by something other 120 S. Ct. 1382 (2000).
than content of the message, such as a straightforward
restriction going only to the time; place, or manner of
speech or other expression. It is easy to see why review - - End Footnotes- - -
of such a regulation may be relatively relaxed. No one { * *56}
has to disagree with any message to find something
Although this type of land -use restriction has even zoning and the mitigation of the effects, stress needs to
been called a variety of time, place, or manner be placed on the empirical character of the
regulation, id., at 46, equating a secondary- effects demonstration available. See Metromedia, Inc. v. San
zoning regulation with a mere regulation of time, Diego, 453 U.S. 490, 510, 69 L. Ed. 2d 800, 101 S.
place, or manner jumps over an important difference Ct. 2882 (1981) (Judgments ... defying objective
between them. A restriction on loudspeakers has no evaluation must be carefully scrutinized to
obvious relationship to the substance of what is determine if they are only a public rationalization of an
broadcast, while a zoning regulation of businesses in impermissible purpose ); Young, 427 U.S. at 84
adult expression just as obviously does. And while it (Powell, J., concurring) ( "Courts must be alert ... to the
may be true that an adult business is burdened only possibility of using the power to zone as a pretext for
because of its secondary effects, it is clearly burdened suppressing expression "). The weaker the
only if its expressive products have adult content. demonstration of facts distinct from disapproval of the
Thus, the Court has recognized that this kind of "adult" viewpoint, the greater the likelihood that
regulation, though called content neutral, occupies a nothing more than condemnation of the viewpoint
kind of limbo between full - blown, content -based drives the regulation. n3
restrictions and regulations that apply without any
reference to the substance of what is said. Id., at 47. Footnotes
It would in fact make sense to give this kind of zoning
regulation a First Amendment label of its own, and if n3 Regulation of commercial speech,
we called it content correlated, we would not only which is like secondary- effects zoning in
describe it for what it is, but keep alert to a risk of being subject to an intermediate level of
content -based regulation that it poses. The risk lies in First Amendment scrutiny, see Central
the fact that when a law applies { * *57} selectively Hudson Gas & Elec. Corp. v. Public Serv.
only to speech of particular content, the more precisely Comm'n of N. Y., 447 U.S. 557, 569, 65 L.
the content is identified, the greater is the opportunity Ed. 2d 341, 100 S. Ct. 2343 (1980),
for government censorship. Adult speech refers not provides an instructive parallel in the cases
merely to sexually explicit content, but to speech enforcing an evidentiary requirement to
reflecting a favorable view of being explicit about sex ensure that an asserted rationale does not
and a favorable view of the practices it depicts; a cloak an illegitimate governmental motive.
restriction on adult content is thus also a restriction See, e.g., Rubin v. Coors Brewing Co.,
turning on a particular viewpoint, of which the 514 U.S. 476, 487, 131 L. Ed. 2d 532, 115
government may disapprove. S. Ct. 1585 (1995); Edenfield v. Fane,
This risk of viewpoint discrimination is subject to a 507 U.S. 761, 123 L. Ed. 2d 543, 113 S.
simple safeguard, Ct. 1792 (1993). The government's
relatively p guard, however. If combating "burden is not satisfied by mere
secondary effects of property devaluation and crime is
truly the reason for the regulation, it is possible to speculation or conjecture," but only by
show by empirical evidence that the effects exist, that "demonstrat[ing] that the harms [the
they are caused by the expressive activity subject to the government] recites are real and that its
zoning, and that the zoning can be expected either to restriction will in fact alleviate them to a
ameliorate them or to enhance the capacity of the material degree." Id, at 770 -771. For
government to combat them (say, by concentrating unless this "critical" requirement is met,
them in one area), without suppressing the expressive Rubin, supra, at 487, "a State could with
activity itself. This capacity of zoning regulation to ease restrict commercial speech in the
address the practical problems without eliminating the service of other objectives that could not
s speech is, after all, the only themselves justify a burden on commercial
P y possible excuse for
expression," " E den eld supra, at 771.
speaking of secondary- effects zoning { * *58} as akin P f
to time, place, or manner regulations.
In examining claims that there are causal relationships - - -End Footnotes- - -
between adult businesses and an increase in secondary { * *59}
effects (distinct from disagreement), and between
17
Equal stress should be placed on the point that any causal relationship between the breakup policy and
requiring empirical justification of claims about elimination or regulation of secondary effects.
property value or crime is not demanding anything II
Herculean. Increased crime, like prostitution and Our cases on the subject have referred to studies,
muggings, and declining property values in areas
surrounding adult businesses, are all readily undertaken with varying degrees of formality, showing
observable, often to the untrained eye and certainly to the geographical correlations between the presence or
the police officer and urban planner. These harms can concentration of adult business establishments and
be shown by police reports, crime statistics, and studies enhanced crime rates or depressed property values.
See, e.g., Renton, sup ra, at 50 -51; Young, supra, at
of market value, all of which are within a
municipality's capacity or available from the distilled 55. Although we have held that intermediate scrutiny
experiences of comparable communities. See, e.g., of secondary- effects legislation does not demand a
Renton, supra, at 51; Young, supra, at 55. fresh evidentiary study of its factual basis if the
published results of investigations elsewhere are
And precisely because this sort of evidence is readily "reasonably" thought to be applicable in a different
available, reviewing courts need to be wary when the municipal setting, Renton, supra, at 51 -52, the city
government appeals, not to evidence, but to an here took responsibility { * *62} to make its own
uncritical common sense in an effort to justify such a enquiry. App. 35 -162. As already mentioned, the study
zoning restriction. It is not that common sense is was inconclusive as to any correlation between adult
always illegitimate in First Amendment demonstration. business and lower property values, id, at 45, and it
The need for independent proof varies with the point reported no association between higher crime rates and
that has to be established, and zoning can be supported any isolated adult establishments. But it did find a
by common experience when there is no reason to geographical correlation of higher concentrations of
question it. We have appealed to common sense in adult establishments with higher crime rates, id, at 43,
analogous { * *60} cases, even if we have disagreed and with this study in hand, Los Angeles enacted its
about how far it took us. See Erie v. Pap's A. M., 529 1978 ordinance requiring dispersion of adult stores and
U.S. 277, 300 -301, 146 L. Ed. 2d 265, 120 S. Ct. 1382 theaters. This original position of the ordinance is not
(2000) (plurality opinion); id, at 313, and n. 2 challenged today, and I will assume its justification on
(SOUTER, J., concurring in part and dissenting in the theory accepted in Young, that eliminating
part). But we must be careful about substituting concentrations of adult establishments will spread out
common assumptions for evidence, when the evidence the documented secondary effects and render them
is as readily available as public statistics and municipal more manageable that way.
property valuations, lest we find out when the evidence
is gathered that the assumptions are highly debatable. The application of the 1983 amendment now before us
The record in this very case makes the point. It has is, however, a different matter. My concern is not with
become a common- place, based on our own cases, that the assumption behind the amendment itself, that a
concentrating adult establishments drives down the conglomeration of adult businesses under one roof, as
value of neighboring property used for other purposes. in a minimall or adult department store, will produce
undesirable secondary effects comparable to what a
See Renton, 475 U.S. at 51; Young, 427 U.S. at 55. In cluster of separate adult establishments brings about,
fact, however, the city found that general assumption ante, at 8. { * *63} That may or may not be so. The
unjustified by its 1977 study. App. 39, 45. assumption that is clearly unsupported, however, goes
The lesson is that the lesser scrutiny applied to to the city's supposed interest in applying the
content - correlated zoning restrictions is no excuse for a amendment to the book and video stores in question,
government's failure to provide a factual demonstration and in applying it to break them up. The city, of
for claims it makes about secondary effects; on the course, claims no interest in the proliferation of adult
contrary, this is what demands the demonstration. See, establishments, the ostensible consequence of splitting
e.g., Schad v. Mount Ephraim, 452 U.S. 61, 72 -74, the sales and viewing activities so as to produce two
68 L. Ed. 2d 671, 101 S. Ct. 2176 (1981). ("61} In stores where once there was one. Nor does the city
this case, however, the government has not shown that assert any interest in limiting the sale of adult
bookstores containing viewing booths, isolated from expressive material as such, or reducing the number of
other adult establishments, increase crime or produce adult video booths in the city, for that would be clear
other negative secondary effects in surrounding content -based regulation, and the city was careful in its
neighborhoods, and we are thus left without substantial 1977 report to disclaim any such intent. App. 54. n4
justification for viewing the city's First Amendment
restriction as content correlated but not simply content
Footnotes
based. By the same token, the city has failed to show
n4 Finally, the city does not assert an Rather, the city apparently assumes that a bookstore
interest in curbing any secondary effects selling videos and providing viewing booths produces
within the combined bookstore- arcades. In secondary effects of crime, and more crime than would
Hart Book Stores, Inc. v. Edmisten, 612 result from having a single store without booths in one
F.2d 821 (1979), the Fourth Circuit upheld part of town and a video arcade in another. n5 But the
a similar ban in North Carolina, relying in city neither says this in so many words nor proffers any
part on a county health department report evidence to support even the simple proposition that an
on the results of an inspection of several of otherwise lawfully located adult bookstore combined
the combined adult bookstore -video with video booths will produce any criminal effects.
arcades in Wake County, North Carolina. The Los Angeles study treats such combined stores as
Id, at 828 -829, n. 9. The inspection one, see id, at 81 -82, and draws no general conclusion
revealed unsanitary conditions and that individual stores spread apart from other adult
evidence of salacious activities taking establishments (as under the basic Los Angeles
place within the video cubicles. Ibid. The ordinance) are associated with any degree of criminal
city introduces this case to defend its activity above the general norm; nor has the city called
breakup policy although it is not clear from the Court's attention to any other empirical study, or
the opinion how separating these video even anecdotal police evidence, that supports the city's
arcades from the adult bookstores would assumption. In fact, if the Los Angeles study sheds any
deter the activities that took place within light whatever on the city's position, it is the light of
them. In any event, while Renton v. skepticism, for we may fairly suspect that the study
Playtime Theatres, Inc., 475 U.S. 41, 89 said nothing about the secondary effects of
L. Ed. 2d 29, 106 S. Ct. 925 (1986), freestanding stores because no effects were observed.
allowed a city to rely on the experiences { * *65} The reasonable supposition, then, is that
and studies of other cities, it did not 'splitting some of them up will have no consequence
dispense with the requirement that for secondary effects whatever. n6
"whatever evidence the city relies upon
[be] reasonably believed to be relevant to Footnotes
the problem that the city addresses," id, at
51 -52, and the evidence relied upon by the
Fourth Circuit is certainly not necessarily n5 The plurality indulges the city's
relevant to the Los Angeles ordinance. assumption but goes no further to justify it
Since November 1977, five years before than stating what is obvious from what the
the enactment of the ordinance at issue, city's study says about concentrations of
Los Angeles has regulated adult video adult establishments (but not isolated
booths, prohibiting doors, setting minimum ones): the presence of several adult
levels of lighting, and requiring that their businesses in one neighborhood draws "a
interiors be fully visible from the entrance greater concentration of adult consumers to
to the premises. Los Angeles Municipal the neighborhood, [which] either attracts or
Code §§ 103.101(i), (j). Thus, it seems less generates criminal activity." Ante, at 8.
likely that the unsanitary conditions
identified in Hart Book Stores would exist
in video arcades in Los Angeles, and the n6 Renton, the Court approved a zoning
city has suggested no evidence that they ordinance "aimed at preventing the
do. For that reason, Hart Book Stores gives secondary effects caused by the presence
no indication of a substantial govemmental of even one such theater in a given
interest that the ban on multiuse adult neighborhood." 475 U.S. at 50. The city,
establishments would further. however, does not appeal to that decision
to show that combined bookstore- arcades
- - -End Footnotes- - - isolated from other adult establishments,
{ * *64} like the theaters in Renton, give rise to
negative secondary effects, perhaps
19
recognizing that such a finding would only argues that more recent studies show no
call into doubt the sensibility of the city's such thing, but this case involves no such
decision to proliferate such businesses. See challenge to the previously accepted causal
ante, at 10. Although the question may be connection.
open whether a city can rely on the
experiences of other cities when they
contradict its own studies, that question is n8 JUSTICE KENNEDY would indulge
not implicated here, as Los Angeles relies the city in this speculation, so long as it
exclusively on its own study, which is could show that the ordinance will "leave
tellingly silent on the question whether the quantity and accessibility of speech
isolated adult establishments have any substantially intact." Ante, at 7 (opinion
bearing on criminal activity. concurring in judgment). But the
suggestion that the speculated
- - -End Footnotes- - - consequences may justify content -
{ * *66} correlated regulation if speech is only
slightly burdened turns intermediate
The inescapable point is that the city does not even scrutiny on its head. Although the goal of
claim that the 1977 study provides any support for its intermediate scrutiny is to filter out laws
assumption. We have previously accepted studies, like that unduly burden speech, this is achieved
the city's own study here, as showing a causal by examining the asserted govemmental
connection between concentrations of adult business interest, not the burden on speech, which
and identified secondary effects. n7 Since that is an must simply be no greater than necessary
acceptable basis for requiring adult businesses to to further that interest. Pap's A. M., 529
disperse when they are housed in separate premises, U.S. at 301; see also n. 2, supra. Nor has
there is certainly a relevant argument to be made that JUSTICE KENNEDY even shown that this
restricting their concentration at one spacious address ordinance leaves speech "substantially
should have some effect on sales, traffic, and effects in intact." He posits an example in which two
the neighborhood. But even if that argument may adult stores draw 100 customers, and each
justify a ban on adult "minimalls," ante, at 8, it business operating separately draws 49.
provides no support for what the city proposes to do Ante, at 9. It does not follow, however, that
here. The bookstores involved here are not a combined bookstore- arcade that draws
concentrations of traditionally separate adult 100 customers, when split, will yield a
businesses that have been studied and shown to have bookstore and arcade that together draw
an association with secondary effects, and they nearly that many customers. Given the now
exemplify no new form of concentration like a mall double outlays required to operate the
under one roof. They are combinations of selling and businesses at different locations, see infra,
viewing activities that have commonly been combined, at 15, the far more likely outcome is that
and the plurality itself recognizes, ante, at 10, that no the stand -alone video store will go out of
study conducted by the city has reported that this business. (Of course, the bookstore owner
{ * *67} type of traditional business, any more than any could, consistently with the ordinance,
other adult business, has a correlation with secondary continue to operate video booths at no
effects ifi the absence of concentration with other adult charge, but if this were always
establishments in the neighborhood. And even if commercially feasible then the city would
splitting viewing booths from the bookstores that face the separate problem that under no
continue to sell videos were to turn some customers theory could a rule simply requiring that
away (or send them in search of video arcades in other video booths be operated for free be said to
neighborhoods), it is nothing but speculation to think reduce secondary effects.)
that marginally lower traffic to one store would have
any measurable effect on the neighborhood, let alone
- - -End Footnotes- - -
an effect on associated crime that has never been { * *68}
shown to exist in the first place. n8
Nor is the plurality's position bolstered, as it seems to
Footnotes think, ante, at 11, by relying on the statement in
Renton, that courts should allow cities a "'reasonable
opportunity to experiment with solutions to admittedly
n7 As already noted, n. 1, supra, amicus serious problems, "' 475 U.S. at 52. The plurality
First Amendment Lawyers Association overlooks a key distinction between the zoning
regulations at issue in Renton and Young (and in Los scheme, ante, at 13, is indulgent to an
Angeles as of 1978), and this new Los Angeles unrealistic degree, as the record in this case
breakup requirement. In those two cases, the shows. When the original dispersion
municipalities' substantial interest for purposes of ordinance was enacted in 1978, the city's
intermediate scrutiny was an interest in choosing study showing a correlation between
between two strategies to deal with crime or property concentrations of adult business and higher
value, each strategy tied to the businesses' location, crime rates showed that the dispersal of
which had been shown to have a causal connection adult businesses was causally related to the
with the secondary effects: the municipality could city's law enforcement interest, and that in
either concentrate businesses for a concentrated turn was a fair indication that the city's
regulatory strategy, or disperse them in order to spread concern was with the secondary effect of
out its regulatory efforts. The limitations on location higher crime rates. When, however, the
required no further support than the factual basis tying city takes the further step of breaking up
location to secondary effects; the zoning approved in businesses with no showing that a
those two cases had no effect on the way the owners of traditionally combined business has any
the stores carried on their adult businesses beyond association with a higher crime rate that
controlling location, ( * *69} and no heavier burden could be affected by the breakup, there is
than the location limit was approved by this Court. no indication that the breakup policy
addresses a secondary effect, but there is
The Los Angeles ordinance, however, does impose a reason to doubt that secondary effects are
heavier burden, and one lacking any demonstrable the city's concern. The plurality seems to
connection to the interest in crime control. The city no ask us to shut our eyes to the city's failings
longer accepts businesses as their owners choose to by emphasizing that this case is merely at
conduct them within their own four walls, but bars a the stage of summary judgment, ante, at
video arcade in a bookstore, a combination shown by 11, but ignores the fact that at this
the record to be commercially natural, if not universal. summary judgment stage the city has made
App. 47 -51, 229 -230, 242. Whereas Young and Renton it plain that it relies on no evidence beyond
gave cities the choice between two strategies when
each was causally related to the city's interest, the the 1977 study, which provides no support
for the city
plurality today gives Los Angeles a right to
s action.
"experiment" with a First Amendment restriction in
response to a problem of increased crime that the city - - -End Footnotes- - -
has never even shown to be associated with combined { * *71}
bookstore - arcades standing alone. But the
government's freedom of experimentation cannot And concern with content -based regulation targeting a
displace its burden under the intermediate scrutiny viewpoint is right to the point here, as witness a fact
standard to show that the restriction on speech is no that involves no guesswork. If we take the city s
greater than essential to realizing an important breakup policy at its face, enforcing it will mean that in
objective, in this case policing crime. Since we cannot every case two establishments will operate instead of
make even a best guess that the city's breakup policy the traditional one. Since the city presumably does not
will have any effect on crime or { * *70} law wish merely to multiply adult establishments, it makes
enforcement, we are a very far cry from any assurance sense to ask what offsetting gain the city may obtain
against covert content based regulation. n9 from its new breakup policy. The answer may lie in the
fact that two establishments in place of one will entail
two business overheads in place of one: two monthly
Footnotes rents, two electricity bills, two payrolls. Every month
business will be more expensive than it used to be,
n9 The plurality's assumption that the perhaps even twice as much. That sounds like a good
city's "motive" in applying secondary- strategy for driving out expressive adult businesses. It
effects zoning can be entirely sounds, in other words, like a policy of content -based
compartmentalized from the proffer of regulation.
evidence required to justify the zoning I respectfully dissent.
21