ABSTRACT
Billboards are outdoor signs that have been used to communicate political, social, and commercial messages throughout American history. Billboards can foster a healthy marketplace, not only of goods and services but also of ideas. Using the police power, local governments have sought to control or even ban billboards due to their adverse effects on public safety and aesthetics. Most of the health, safety, and morals objections to billboards can be overcome in their manner of construction. Local and state laws regulating billboards were generally considered to be a valid exercise of the police power until the early 1980s, when the US Supreme Court found that the free speech concerns arising from billboard regulations merited First Amendment analysis. A San Diego ordinance forbade off-site commercial and all noncommercial billboard advertising unless the noncommercial advertising fell under one of twelve specific exceptions; on-site commercial advertising was permissible.
