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Keywords

statuteappealcorporation

statuteappealpatentconstitutional law

Related Cases

Brockett v. Spokane Arcades, Inc., 472 U.S. 491, 105 S.Ct. 2794, 86 L.Ed.2d 394, 53 USLW 4793

Facts

The case involved a challenge to the constitutionality of Washington's moral nuisance statute, which defined 'prurient' to include material that incites lust. Various individuals and corporations selling sexually oriented materials sought injunctive and declaratory relief against the statute, claiming it violated their First Amendment rights. The District Court upheld the statute, but the Court of Appeals reversed, declaring it unconstitutional in its entirety. The state and county officials appealed the decision.

Issue

Did the Court of Appeals err in invalidating the Washington moral nuisance statute in its entirety?

The question in these cases is whether the Court of Appeals for the Ninth Circuit erred in invalidating in its entirety a Washington statute aimed at preventing and punishing the publication of obscene materials.

Rule

The Supreme Court held that a statute may be partially invalidated if it contains a severability clause and if the invalid provisions are independent of the constitutional applications. The Court emphasized that the definition of obscenity must not extend to materials that provoke only normal sexual responses, and that the First Amendment does not protect obscene speech.

To be obscene, publication must, taken as a whole, appeal to prurient interest, contain patently offensive depictions or descriptions of specified sexual conduct, and on the whole have no serious literary, artistic, political, or scientific value.

Analysis

The Court reasoned that the Washington statute should not have been invalidated in its entirety because it contained a severability clause. The definition of 'prurient' could be interpreted to exclude normal sexual interest, allowing the statute to remain effective in regulating obscenity. The Court noted that the overbreadth identified by the Court of Appeals did not warrant a complete invalidation, as the statute could still function without the offending term.

Facial invalidation of the statute was nevertheless improvident. We call to mind two of the cardinal rules governing the federal courts: 'never to anticipate a question of constitutional law in advance of the necessity of deciding it; the other never to formulate a rule of constitutional law broader than is required by the precise facts to which it is to be applied.'

Conclusion

The Supreme Court reversed the Court of Appeals' decision, holding that the Washington moral nuisance statute should not have been invalidated in its entirety and remanded the case for further proceedings.

The judgment of the Court of Appeals is accordingly reversed, and the case is remanded for further proceedings consistent with this opinion.

Who won?

The prevailing party in this case was the state of Washington, as the Supreme Court reversed the Court of Appeals' ruling that had invalidated the moral nuisance statute. The Court found that the statute contained a severability clause, allowing it to remain effective even if parts of it were deemed unconstitutional. The Court emphasized the importance of not extending the invalidation of a statute further than necessary, particularly in cases involving First Amendment rights.

The Court of Appeals erred in facially invalidating the statute in its entirety.

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