Chapter 7: Manner Regulation - Licensing

Quick Guide to Chapter 7:

What can a community do to prevent unlawful sexual activity from occurring in "peep show" booths in "adult bookstores" or in nude dancing establishments?

 

Ordinances are uniformly upheld that require doors to be removed from booths, visibility into the booths from an on-duty manager, and minimum lighting requirements. In addition, you can forbid sexual contact on the premises; in a nude dancing establishment, you can prohibit "couch dancing" or any other contact between dancers and patrons, and can require dancers to stay on stage and maintain a certain distance from patrons. (7.1)

 

What type of business and personal licensing can you require of SOBs, their owners, and employees?

 

While this is an area fraught with constitutional difficulties, you can clearly require SOBs to pay license fees that are revenue neutral so that background checks can be run on owners for relevant criminal conduct, and to determine compliance with health and safety codes along with other aspects of SOB regulation. To be constitutional the licensor must be without discretion, but merely following a set of rules and guidelines for issuing the license. The ordinance must contain specific time limits for responding to license applications, and prompt judicial review must be available when a license is denied. Employees may also be licensed so that the police can check for a criminal background. (7.2)


There are two primary methods of regulating the manner of operation for sexually oriented businesses. These are: regulating the interior configuration of SOBs; and licensing SOBs, their owners and employees.

7.1-  Interior Configuration

The problems associated with "peep show" booths were documented in graphic and repulsive detail in Chapter 2 of this book. To summarize, the typical "adult" bookstore has dim, smelly and private back rooms where for a quarter patrons can view brief sexually explicit videos. Functionally, however, these "peep show" booths exist as a meeting spot for men to engage in anonymous oral and anal intercourse, or for men to expose themselves and masturbate. Owners of sexually oriented businesses know this because they are aware of the holes in the walls, and they hire people to clean up the bodily fluids and used condoms from the booths.

 

In one California case, a former bookstore patron presented a lengthy declaration to the court:

 

My only purpose going to the bookstore was to pick up a sex partner. I would stay out cruising the parking lot, and then would stop and park. Only a few minutes would pass and I would have a male approach me and ask me what I would like. I would state I was just looking for action. The next question that was almost always asked, are you a cop. I would state no, and almost instantly he would start feeling his private area and state I will give you head for $20. I stated I didn't do sex for money. I would then go inside the bookstore. I would say that there was usually four to five solicitors in the lot at one time. I constantly watched guys get into the cars (guys that approached me for money) and drive off and return 20 to 30 minutes later. I knew they were only driving a few blocks away or around the comer and having sex in the car. Most of the time it wouldn't take long and the same person would be back in another car, driving off with another person. Mostly it was younger guys picking up on older men. On a normal cruising night there could be 50 to 100 cars just cruising the area looking for sex. Most of the time, most just cruised flashing lights, parking in park­ing lots, getting out talking to each other. Then usually one guy would get into the other guy's car and drive off for a half hour and then return. Cars were always stopping in the middle of the road, driveways, and business parking lots. After the contact was made, sex usually occurred in the surrounding neighborhood. This is the way I usually conducted my activity. I would say that 65-70 percent was done this way. Then I would hit the bookstores. I would state from my personal experience that 90 percent of the bookstore's intention for business is to promote sexual activity. I looked for bookstores that had doors that locked so I could have sex. I never occupied another booth with another person because I was afraid of being caught. But, I was very seldom in one, when I didn't see two guys coming out of a stall. I looked for bookstores that had holes cut into the walls. These holes were big enough that oral sex could be conducted. One time I thought I was having oral sex through the hole and discovered it was anal. Many times I would enter the booth and the guy would shove his penis through the hole without even saying a word, wanting head. Many times I was offered a rubber so I could have anal sex. Always the bookstore was dirty. I would see used condoms on the floor, dirty paper towel, semen on the floor and advertisements written on the walls for sex and phone numbers. People always watched who went into a certain booth, and if they were interested, they would go into the next one to have sex. Most of the time I would watch other sex acts from the hole. I got to know a lot of male prostitutes even though I wouldn't pay for their services. I [k]new one guy by the name of Tom who showed me $200 he made in one night. Tom told me he also did heroin and had been in and out of jail for robbery and drugs. Several times I would give Tom a ride to Buena-Clinton area where I [k]new he bought drugs. I would never give him a ride back because I didn't want to get caught with him with drugs and I didn't do drugs. Tom always offered me some and I declined. Tom always told me how much money he made doing prostitution and drugs. He also told me how he would jack roll older clients because they couldn't defend themselves and they wouldn't report it to the police because of publicity. I observed Tom beat a guy up one night outside the bookstore for not paying him back for drugs. Then another night this male prostitute by the name of Carl stated he had this girl I could get with for $30. I gave him the money and the girl wasn't there. I was going to beat Carl up for ripping me off. Carl was arrested for robbery before I got the chance.

 

I went to the bookstore mainly for sexual purposes. There was nowhere else I could go where I could find every­thing I was looking for. I [k]new the bookstore owners knew what was going on but was only looking for money. I look back on how these bookstores have ruined my life. They aren't there for personal enjoyment.  They are there to promote sex, violence, prostitution and selling of drugs. When a[n] owner knows illegal activity is happening and does nothing to prevent it, he should be closed down for public safety. This is illustrated by holes in the wall for sex. If holes weren't there or doors weren't there, I can guarantee there would be none or little business.

 

 

Declaration of Herbert Hall in People v. Welty, Case No. X-605395, Superior Court of the State of California, County of Orange (November 8, 1989).

 

Because of the rights of communities to legislate in the interest of the public health and safety, and because these establishments so clearly are health and safety hazards, a number of regulations of “peep show" booths have been enacted, and they are almost uniformly upheld. All of these regulations have the expressed purpose of preventing dangerous and illegal public sexual activity from occurring. They do not interfere at all with the right of patrons to view sexually explicit videos; they simply regulate the manner in which those videos can be watched.

 

Open Booths

 

One of the most effective methods of preventing dangerous public sexual activity in "peep show" booths is to require one side of every booth to be open so that the interior is visible by direct line of sight from the manager's station, or even from anywhere else in the main part of the store. E.g., Pleasureland Museum, Inc. v. Beutter, 288 F.3d 988, 1003 (7th Cir. 2002) (holding that open booth restrictions are content-neutral and aimed at secondary effects); Matney v. County of Kenosha, 86 F.3d 692, 698 (7th Cir. 1996) (“[W]e thus conclude … that [open booth restrictions are] a constitutional time, place, and manner restriction.”). The ordinance may also require a manager to be on duty in the manager's station at all times the store is open, and hold him responsible for making sure the "peep show" booth rules are followed. The SOB can be required to submit detailed blueprints showing the layout of the store and demonstrat­ing compliance with the open booth and manager's station requirements. See, e.g., Pleasureland Museum, Inc. v. Beutter, 288 F.3d 988, 994 (7th Cir. 2002) (“[T]he [permit] application shall [include] a diagram of the premises….”).

 

One Person Per Booth

 

Another typical regulation that is normally upheld is a requirement that the private viewing rooms be used by only one person at a time, again to prevent unlawful sexual activity between patrons. The manager can also be held responsible for making certain no more than one person is in each booth. E.g., Bamon Corp. v. City of Dayton, 730 F.Supp. 80 (S.D. Ohio 1990) aff’d 923 F.2d 470 (6th Cir. 1991).

 

Minimum Lighting Requirements

 

Obviously, it will do no good to have "peep show" booths open by direct line of sight to a manager's station if they are so dark that no one can see into them and observe whether more than one per­son is inside and whether illegal public sex acts are occurring. Thus, courts have upheld minimum lighting requirements, usually put in terms of footcandles measured at floor level. See, e.g., N.W. Enterprises, Inc. v. City of Houston, 27 F.Supp.2d 754, 826 (S.D. Tex 1998) (regulating minimum lighting requirement allowed as a content-neutral regulation aimed at secondary effects).

 

No "Glory Holes"

 

"Glory holes" are small holes punched in the side of "peep show" booth walls so that patrons can engage in anonymous anal or oral intercourse. It is permissible to require that managers ensure that walls are continuous from floor to ceiling and without any holes or openings. See Bamon Corp. v. City of Dayton, 923 F.2d at 471 (upheld ordinance forbidding holes in peep booths).


 

Cleaning Requirements

 

Again for reasons of public health, the manager can be required to maintain all booths in a clean manner, free from semen, urine, feces, needles and trash. E.g., Scope Pictures, of Missouri, Inc. v. City of Kansas City, 140 F.3d 1201, 1206 (8th Cir. 1998) (holding that a regulation requiring booths to be “clean and sanitary” is not vague).

 

The typical challenge to "peep show" booth regulations is grounded in the First Amendment right to view sexually explicit fare, along with the constitutional "right to privacy," which ostensibly can be found in either the Fourth or Ninth Amendment if you know where to look.

 

The U.S. Court of Appeals for the Sixth Circuit rejected both of those constitutional arguments in Bamon Corporation V. City of Dayton, 923 F.2d 470 (6th Cir. 1991). The court established that Dayton's open booth ordinance was a content-neutral regulation of the manner in which sexually explicit videos could be shown in a public place. It credited the government's legitimate purpose of preventing the spread of sexual diseases, and held that the ordinance burdened speech no more than necessary to further the gov­ernment's interest:

 

[The ordinance] neither limits the number of viewing booths, nor attempts to regulate the material shown in the booths. The Dayton ordinance does not, in any real fashion, limit the availability of video booths as a means of viewing sexually explicit material. Thus, we find that the Dayton ordinance is a valid time, place and manner regulation.

 

923 F.2d at 474. The court went on to reject the right to privacy argument, holding that whatever constitutional rights belong to citizens to view sexually explicit films in their home, viewing them in places of public accommodation removed any privacy claim. Id.

 

Open booth ordinances have also been challenged on equal protection grounds because of the differing treatment of "peep show" booths showing sexually explicit fare, versus hotel rooms offering similar movies. A federal court in Wisconsin stated that a city could rationally conclude that unsanitary sexual behavior was more of a problem in small rooms devoted solely to private movie watching than in hotel rooms which served a variety of other functions. Libra Books, Inc. v. City of Milwaukee, 818 F.Supp. 263 (E.D.Wis. 1993).

 

The Eighth Circuit in Doe V. City of Minneapolis, 898 F.2d 612 (8th Cir. 1990), upheld a typical ordinance against the usual constitutional challenges, including an equal protection challenge, while also rejecting a claim that the owner's First Amendment rights were violated because the ordinance deprived him of the ability to survive economically and continue offering sexually explicit fare. The court was not persuaded: "[The owner] has a first amendment right to display his videos and dancers, but he does not have a guaranteed right to make a profit." 898 F.2d at 621.

 

Many other cases have upheld similar interior configuration requirements. See Pleasureland Museum, Inc. v. Beutter, 288 F.3d 988, (7th Cir. 2002); Scope Pictures, of Missouri, Inc. v. City of Kansas City, 140 F.3d 1201 (8th Cir. 1998); Spokane Arcade, Inc. v. City of Spokane, 75 F.3d 663 (9th Cir. 1996); Mitchell v. Commission on Adult Entertainment Establishments of State of Del., 10 F.3d 123 (3d Cir. 1993); Berg v. Health and Hosp. Corp. of Marion County, Ind., 865 F.2d 797, 802-803 (7th Cir. 1989); Wall Distributors, Inc. v. City of Newport News, Va., 782 F.2d 1165 (4th Cir. 1986); Ellwest Stereo Theatres, Inc. v. Winner, 681 F.2d 1243 (9th Cir. 1982); Matney v. County of Kenosha, 887 F.Supp. 1235 (E.D.Wis. 1995), aff’d 86 F.3d 692 (7th Cir. 1996); Doe v. City of Minneapolis, 693 F.Supp. 774 (D.Minn. 1988); Postscript Enterprises v. City of Bridgeton, 699 F.Supp. 1393 (E.D. Mo. 1988); Broadway Books, Inc. v. Roberts, 642 F.Supp. 486 (E.D. Tenn. 1986); SDJ Inc. v. City of Houston, 636 F.Supp. 1359 (S.D. Tex. 1986); Dumas v. City of Dallas, 648 F.Supp. 1061 (N.D. Tex. 1986), aff'd 837 F.2d 1298 (5th Cir. 1988); Moody v. Board of County Commissioners, 697 P.2d 1310 (Kan. 1985); City of Ramsey v. Amusement Center, Inc., 498 N.W.2d 25 (Minn.App. 1993); City of Cleveland v. Fisher, 611 N.E.2d 1016 (Cle.Mun.Crt. 1992).

 

When a sexually oriented business knowingly allows sexual activities within "peep booths" or on the premises, it is constitutionally permissible to require the closure of the establishment. This is allowed despite First Amendment claims of an unconstitutional prior restraint. Thus, a city may constitutionally adopt an ordinance requiring closure of an entire premise as a public health nui­sance if the establishment knowingly allows prostitution, lewdness or assignation on the premises.

 

The Supreme Court in Arcara V. Cloud Books, Inc., 478 U.S. 697 (1986), squarely addressed this issue. In Arcara, an "adult" property use which sold sexually explicit magazines also contained "peep booths." The establishment routinely allowed "masturbation, fondling, and fellatio by patrons on the premises of the store, all within the observation of the proprietor." 478 U.S. at 699. The Court permitted the closure of the entire premises under a public health law as a valid, content-neutral time, place and manner regulation:

 

The legislation providing the closure sanction was directed at unlawful conduct having nothing to do with books or other expressive activities. Bookselling in an establishment used for prostitution does not confer First Amendment coverage to defeat a valid statute aimed at penalizing and terminating illegal uses of premises. The legislature properly sought to protect the environment of the community by directing the sanctions at premises knowingly used for lawless purposes.

 

Id., 478 U.S. at 707. Similarly, see Commonwealth V. Croatan Books, Inc., 323 S.E.2d 86, 89 (Va. 1984), which upheld closure of a pornographic bookstore based on evidence that homosexuals congregated there to engage in sexual acts.[1]

 

Closing sexually oriented businesses as public nuisances will be explored in more detail in     Chapter 9.

 

Another aspect of regulating the interior of sexually oriented businesses applies to public nude dancing establishments where "lap dancing" and other sexual contact occurs between dancers and patrons. See Hang On, Inc. v. City of Arlington, 65 F3d 1248 (5th Cir. 1995). These regulations may include the required use of railings and stages to keep a distance between dancers and patrons. See Jake's, Ltd., Inc. v. City of Coates, 284 F.3d 884, 891 (8th Cir. 2002) (two feet above the floor, six feet required between patrons and dancers, and no tipping); DLS, Inc. v. City of Chattanooga, 107 F.3d 403, 411 (6th Cir. 1997) (requiring six-foot distance between dancer and people to help combat secondary effects); KEV Inc. v. Kitsap County, 793 F.2d 1053 (9th Cir. 1986) ; Parker V. Whitfield County, 463 S.E.2d 116 (Ga. 1995).

7.2 - Licensing

In order to keep track of the sexually oriented businesses and employees in a community, it is important to enact a license or permit requirement for SOBs.[2] However, under current caselaw there are significant constitutional problems in many jurisdictions with certain types of licensing regulations that have become almost stan­dard in the typical sexually oriented business ordinance. Some types of licensing regulations are permissible in some jurisdictions and not in others. In this section we will survey licensing options for communities with the objective of pointing out those that have been successful and those that have met with significant constitu­tional difficulties.

 

The governmental interests involved in licensing SOBs and SOB employees are significant. They include the right of communi­ties: to monitor businesses for violations of their building code, to zone and require interior configuration requirements; to monitor employees to make certain criminal laws against public sexual activity, prostitution, and obscenity are not violated; to make cer­tain minors are not being employed in sexual contexts; to protect the public health by verifying that health code and other rules are followed; and to make certain organized crime figures are not involved in ownership and supervision of SOBs.

 

In City of Renton V. Playtime Theatres, Inc., 475 U.S. 41(1986), the Supreme Court established the right of municipalities to treat SOBs differently than other kinds of businesses, based on the type of "speech” SOBs engage in which causes negative secondary effects on the community. We also know from other Supreme Court decisions that municipalities have the authority to license conduct "commonly associated with expression," for example, in requiring parade permits or regulating the location of news racks. City of Lakewood v. Plain Dealer Publishing Co., 486 U.S. 750, 760 (1988). This seems to establish that communities have the right to license SOBs, and many have done so successfully. Seven Seventy Corp. v. County of Clark, 911 P.2d 1187 (Nev. 1996) (SOB enjoined from operating without license).

 

However, because permits and licensing schemes generally require the prior approval of a governmental agency before First Amendment rights can be exercised, they are technically consid­ered prior restraints on speech. As such, they are closely scruti­nized by courts.

 

The general rule on prior restraints is that they are presumptively unconstitutional. Southeastern Promotions, Ltd. V. Conrad, 420 U.S. 546, at 558 (1975). The presumption can be overcome only by meeting the standards enunciated in Freedman V. Maryland, 380 U.S. 51 (1965): the licensing scheme must provide clear standards to guide the decision-making official; there must be prompt judicial review, prior to which the status quo must be maintained; the bur­den of initiating judicial review is on the government and the bur­den of proof is on the government to show the need for the restraint. 380 U.S. at 56-60.

 

For many years it was unclear whether these rules applied to SOB licensing schemes. The Fifth Circuit had rejected the use of prior restraint doctrine in approving a Dallas SOB licensing scheme and treated it as a content-neutral time, place and manner regulation because it was directed at the secondary effects of SOBs. FW/PBS, Inc. v. City of Dallas, 837 F.2d 1298 (5th Cir. 1988). The Supreme Court reversed and struck down the law as facially unconstitutional. 493 U.S. 215 (1990).

 

The Court fractured into three separate camps: three justices agreed with the Fifth Circuit that prior restraint doctrine did not apply; three believed the full Freedman standards should be employed; and three in the middle created a modified Freedman and wrote the plurality opinion striking down the ordinance.

 

According to the plurality, two elements of Freedman were "essential" even if the regulations were content neutral (an issue the Court did not reach): first, the licensor must make the decision whether to issue a license within a brief, specified and reasonable period of time; and second, there must be the possibility of prompt judicial review in case the license is erroneously denied. 493 U.S. at 228. The Court held some elements of Freedman to be not "essential" and therefore the government does not have the burden of seeking judicial review, nor does the government have the burden of proof in court.

 

The Dallas ordinance did not sufficiently limit the discretion of the licensor, according to the Court, because, although the police were given 30 days to approve the issuance of the license, an inspection had to occur before the police could make a decision, and there were no time limits on the inspection. The Court held that the ordinance also failed to provide an avenue for prompt judi­cial review.

 

The fallout from FW/PBS on lower courts has been substantial. Indeed, this remains a developing area of law, with a great deal of on going litigation and new decisions being handed down with reg­ularity. Some decisions on specific provisions of licensing schemes are in total conflict with decisions of other courts.

 

Discretion of Licensor

 

The general principle here is that licensors must not be allowed to accept or reject licenses based on their own predilections or moral considerations, but must instead apply clear, specific guide­lines in a robotic fashion -- in other words, if the business meets certain requirements, the license is essentially automatic.

 

Where an "adult" use zoning ordinance vests unbridled discre­tion in a public official regarding decision making activities, it is susceptible to constitutional attack. It is a settled constitutional principle that any license requirement for an activity related to expression must contain narrow, objective, and definite standards to guide the licensing authority. See Shuttlesworth V. Birmingham, 394 U.S. 147, 150-51(1969); Saja v. New York, 334 U.S. 558 (1948).

 

Any subjective judgments required by an ordinance should be controlled by standards "susceptible of objective measurement." Keyishian V. Board of Regents, 385 U.S. 589, 603-04 (1967). The ordinance must avoid vesting overbroad discretion in the zoning administrator. However, where the findings of an official charged with decision-making authority are based on objectively determinable facts, they are permissible. See Memet V. State, 642 S.W.2d 518, 524 (Tex.App. 1982); Schope V. State, 647 S.W.2d 675, 680 (Tex.Civ.App. 1982).

 

Dumas V. City of Dallas, 648 F.Supp. 1061 (N.D. Tex. 1986), aff'd 837 F.2d 1298 (5th Cir. 1988), addressed an attack on the Dallas "adult" use ordinance on grounds of alleged overbroad discretion. The Fifth Circuit invalidated certain language because it vested an official with the authority to make purely subjective judgments on the "fitness of an applicant." 837 F.2d at 1072. Such "unfettered dis­cretion... cannot survive constitutional scrutiny." Id. at 1073.

 

The Dumas court also rejected a similar challenge to other portions of the ordinance.

 

The findings the police chief must make in licensing sexually oriented businesses are based on objective deter­minable facts, and are thus permissible [cites]. Age restrictions are factually based ... as are determinations of past due fees and taxes ... and false state­ments on application forms. see Schope, 647 S.W.2d at 680 upholding ordinance including such factors);  Bayside Enterprises v. Carson, 470 F.Supp. 1140, 1148 M.D. Fla. 1979) (upholding unpaid tax or fee provision); Genusa v. City of Peoria, 619 F.2d at 1219-20 (upholding provision for false statements). Failure to comply with the Ordinance... m