ABSTRACT

In City of Renton v. Playtime Theatres, Inc., 475 US 41, the US Supreme Court considered the constitutional validity of a municipal zoning ordinance that prohibited adult entertainment theaters from locating within 1,000 feet of any residential zone, single- or multiple-family dwelling, park, or within one mile of any school. The Court had previously upheld the constitutionality of a virtually indistinguishable ordinance in Young v. American Mini Theatres, Inc., 427 US 50, but a majority of the justices in that case were unable to agree on a single rationale for the holding. Renton was another in a line of cases that raised issues of the right to free expression under the First Amendment to the Constitution. As an initial matter, the Renton Court noted that the city's zoning ordinance did not constitute a complete prohibition of adult theaters, but merely required that such theaters be distanced from certain sensitive locations.