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Keywords

lawsuitappealmotionzoningregulationrespondent
motionsummary judgmentzoningregulationrespondentdeclaratory judgment

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City of Renton v. Playtime Theatres, Inc., 475 U.S. 41, 106 S.Ct. 925, 89 L.Ed.2d 29, 54 USLW 4160, 12 Media L. Rep. 1721

Facts

Respondents purchased two theaters in Renton, Washington, intending to exhibit adult films. They filed a lawsuit against the city, claiming that the zoning ordinance prohibiting adult theaters from locating within 1,000 feet of certain areas violated the First and Fourteenth Amendments. The District Court ruled in favor of the city, but the Court of Appeals reversed this decision, leading to the Supreme Court's review.

Respondents purchased two theaters in Renton, Washington, with the intention of exhibiting adult films and, at about the same time, filed suit in Federal District Court, seeking injunctive relief and a declaratory judgment that the First and Fourteenth Amendments were violated by a city ordinance that prohibits adult motion picture theaters from locating within 1,000 feet of any residential zone, single- or multiple-family dwelling, church, park, or school.

Issue

Did the Renton zoning ordinance, which restricted the location of adult motion picture theaters, violate the First and Fourteenth Amendments?

Did the Renton zoning ordinance, which restricted the location of adult motion picture theaters, violate the First and Fourteenth Amendments?

Rule

Content-neutral time, place, and manner regulations are permissible if they serve a substantial governmental interest and do not unreasonably limit alternative avenues of communication.

“Content-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 alternative avenues of communication.

Analysis

The Supreme Court analyzed the Renton ordinance as a content-neutral regulation aimed at addressing the secondary effects of adult theaters on the community. The Court found that the ordinance was designed to serve substantial governmental interests, such as preserving urban quality of life, and that it allowed for reasonable alternative avenues of communication for adult theaters.

The District Court found that the Renton City Council's “predominate” concerns were with the secondary effects of adult theaters on the surrounding community, not with the content of adult films themselves. This finding is more than adequate to establish that the city's pursuit of its zoning interests was unrelated to the suppression of free expression, and thus the ordinance is a “content-neutral” speech regulation.

Conclusion

The Supreme Court reversed the Court of Appeals' decision, holding that the Renton ordinance was constitutional and did not violate the First Amendment.

Held: The ordinance is a valid governmental response to the serious problems created by adult theaters and satisfies the dictates of the First Amendment.

Who won?

City of Renton prevailed because the Supreme Court found that the zoning ordinance was a valid governmental response to the issues posed by adult theaters and did not infringe upon First Amendment rights.

The District Court ultimately entered summary judgment in the city's favor, holding that the ordinance did not violate the First Amendment.

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