Friday, November 15, 2013

Young v. American Mini Theatres, Inc. case brief

Young v. American Mini Theatres, Inc. case brief summary
427 U.S. 50 (1976)

Petitioner city officials appealed the decision from the United States Court of Appeals for the Sixth Circuit, which reversed the judgment of the trial court, which granted summary judgement to the city officials. Respondent theater operators had filed a declaratory suit contending that city ordinances regulating adult-oriented businesses were unconstitutional. The appellate court found both First and Fourteenth Amendment violations.

The City of Detroit passed ordinances regulating the location of adult establishments. Essentially, the businesses could still operate but the ordinances regulated the locations so that such establishments were not concentrated in a certain area.

  • On appeal, the Supreme Court found that the trial court ruled correctly. 
  • The ordinances were constitutional. 
  • Whether the ordinances' procedures for waiver were too vague as to other litigants could not be the basis of the theater operators' claims of vagueness since it was beyond dispute that they intended to offer adult entertainment and there was no evidence they would have sought a waiver. 
  • The ordinances were not a prior restraint on speech. 
  • Persons could still watch adult entertainment. 
  • The restriction was a reasonable attempt to regulate social problems, such as crime, which occurred around adult theaters. 
  • Whether speech could be regulated depended largely on its content. 
  • Sexually oriented materials could be placed in a different classification than other films. 
  • This fact plus the city's legitimate desire to control the effect of adult businesses on surrounding neighborhoods meant that the Equal Protection Clause was not violated.


The decision of the appellate court was reversed. The district court properly entered judgment for the city officials. The theater operators lacked standing to challenge adult business regulations on vagueness grounds. The regulations were not a prior restraint of free speech nor did they violate the Equal Protection Clause.

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