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in mind are that regulations must be narrowlycrafted to address adverse secondary <br /> effects, they must be reasonably related to reduction of these effects and they must be • <br /> capable of objedtive application. If these standards can be met, licensing and other <br /> regulatory provisions may play an important role in preventing unwanted exposure to <br /> 1 sexually oriented materials and in reducing the crime problems associated with <br /> sexually oriented businesses. <br /> 1 • <br /> It is clear that failure to act upon a license application for a sexually oriented <br /> business cannot take the place of regulation. Without justification, denial or failure to <br /> grant a license is a prior restraint in violation of the First Amendment. Parkway Theater <br /> Corporation v. City of Minneapolis, No. 716787, slip. op. (Henn. Co. Dist. Ct., Sept. 24, <br /> 1975). <br /> An ordinance providing for license revocation of an adult motion picture theater if <br /> the licensee is convicted of an obscenity offense is also likely to be held <br /> unconstitutional as a prior restraint of free speech. Alexander v. City of St. Paul, 227 <br /> N.W.2d 370 (Minn. 1975). The Alexander court stated: <br /> a <br /> [W]hen the city licenses a motionpicture theater, it is licensing an <br /> • <br /> activity protected by the First Amendment, and as a result the power of the <br /> city is more limited than when the city licenses activities 'which do not have <br /> First Amendment protection, such as the business of selling liquor or running <br /> a massage parlor. <br /> Id. at 373 •(footnote omitted); see also, Cohen v. City of Daleville, 695 F. Supp. 1168, <br /> 1171 (M.D. Ala. 1988) (past sale of obscene material cannot justify revocation of <br /> license). <br /> However, the courts have permitted communities to deny licenses to sexually <br /> oriented businesses if the person seeking a license has been convicted of other crimes <br /> which are closely related to the operation of sexually oriented businesses. <br /> In Dumas v. City of Dallas, supra, the court reviewed a requirement that a license <br /> applicant not have been convicted of certain crimes within a specified period. Five of <br /> the enumerated crimes were held to be not sufficiently related to the purpose of the <br /> -42- <br /> I <br />