Young v. American Mini Theatres
Young v. American Mini Theatres is a significant Supreme Court case that addressed the intersection of zoning laws and First Amendment rights regarding sexually explicit materials. The case arose from Detroit's anti-Skid Row ordinance, which mandated that adult entertainment venues be spaced at least five hundred feet away from residential areas. The ordinance was applied uniformly to all adult establishments, regardless of whether their materials were legally deemed obscene. In a narrow 5-4 decision, the Supreme Court upheld the ordinance, with Justice John Paul Stevens articulating that sexually explicit materials receive less protection under the First Amendment than other types of expression. He further noted that the zoning rules did not eliminate access to such materials entirely and that Detroit had a legitimate interest in maintaining neighborhood character. Justice Lewis F. Powell, Jr. concurred, suggesting that the limitations imposed by the ordinance were minimal and incidental. The ruling has since influenced the legal framework surrounding zoning regulations for adult entertainment, with the Court frequently reaffirming the principles established in this case. Young v. American Mini Theatres remains a pivotal reference point in discussions about free speech, community standards, and local governance.
Young v. American Mini Theatres
Date: June 24, 1976
Citation: 427 U.S. 50
Issue: Zoning
Significance: The Supreme Court upheld zoning ordinances that significantly restricted the location of theaters and bookstores dealing in sexually explicit materials.
Detroit’s anti-Skid Row ordinance required that adult stores (those dealing in sexually explicit materials) be dispersed and that they be located at least five hundred feet from residential areas. The ordinance applied to all erotic materials, whether or not they were legally obscene. By a 5-4 vote, the Supreme Court upheld the ordinance. In a plurality opinion, Justice John Paul Stevens made the following points: First, sexually explicit materials were entitled to less First Amendment protection than other forms of expression; second, the zoning regulations did not totally eliminate the availability of the materials; and third, the city had a valid interest in preserving the character of its neighborhoods. In a concurring opinion, Justice Lewis F. Powell, Jr., emphasized that the ordinances placed only “incidental and minimal” limits on the expression of producers and the choice of consumers. The Court has often reaffirmed the basic approach of the Young decision.
