City of Los Angeles v. Alameda Books
United States Supreme Court
535 U.S. 425 (2002)
Los Angeles (defendant) banned two or more adult bookstores or video stores from operating in the same building, relying on a 1977 study correlating adult-store concentration with higher crime and prostitution rates. Alameda Books (plaintiff) sued, claiming the ordinance violated the First Amendment; the trial court granted Alameda summary judgment, and the court of appeals held the 1977 study did not adequately prove the ordinance's specific restriction would reduce crime.
Whether it is sufficient for a municipality to justify a zoning ordinance targeting the secondary effects of adult businesses with evidence that is reasonably believed to be relevant, rather than evidence that directly proves a causal link.