City of Renton v. Playtime Theaters, Inc

Citation. 475 U.S. 41, 106 S. Ct. 925, 89 L. Ed. 2d 29, 1986 U.S.

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Citation475 U.S. 41, 106 S. Ct. 925, 89 L. Ed. 2d 29, 1986 U.S.

Brief Fact Summary. The Petitioner, City of Renton (Petitioner), passed a zoning code restricting the location of adult movie stores within the city.

Synopsis of Rule of Law. A regulation that is content-based on its face may be considered content neutral if it is motivated by a permissible content-neutral purpose.

Points of Law - Legal Principles in this Case for Law Students.

The inquiry for First Amendment purposes is not concerned with economic impact; rather, it looks only to the effect of this ordinance upon freedom of expression.

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Issue. Is this zoning ordinance a violation of First Amendment freedom of speech rights of the Respondent, Playtime Theaters, Inc. (Respondent)?

Held. No. The Petitioner had a substantial interest in avoiding the secondary effects of the adult stores and also allows the stores to be located in other areas of town. Thus, it is a constitutional content-neutral regulation.

Dissent. The ordinance places restrictions on establishments based on the content of the expression within it. Therefore, this is a content-based regulation.

Discussion. Because the ordinance does not ban the adult theaters completely, it is not content-based. As a content-neutral regulation it is subject to the time, place, manner analysis where a regulation is constitutional as long as it serves a substantial governmental interest and does not unreasonably limit alternative avenues of communication.