ABSTRACT
In Young v. American Mini Theatres, Inc., 427 US 50 (1976), the US Supreme Court, in a plurality opinion by Justice John Paul Stevens and with a separate opinion by Justice Lewis F. Powell Jr., narrowly upheld (by a five–four vote) the constitutionality of a Detroit, Michigan, ordinance passed under the city's zoning power to isolate the location of "adult" theaters and bookstores. The ordinance required that adult theaters and bookstores be located at least 1,000 feet from regulated businesses, including bars, hotels, and cabarets, and 500 feet from residential areas. Subsequent decisions refined the meaning of Young. In City of Renton v. Playtime Theatres, Inc., 475 US 41 (1986), the Court revisited the zoning of adult businesses. Using the balancing approach of Justice Powell in Young, Justice William H. Rehnquist upheld a zoning ordinance concentrating the location of adult theaters because their "secondary effects" (drugs, prostitution, traffic, and the like) were harmful to the surrounding community.
