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,I • 1 A. Supreme Court Decisions • The U.S. Supreme Court upheld the validity of municipal adult entertainm zoning regulations in Young v. American Mini Theaters. Inc., 427 U.S. 50, 96 S.Ct. 2, (1976), and City of Renton v. Playtime Theaters, Inc., 475 U.S. 41, 106 S.Ct. 926 (198t In Young, the Court upheld the validity of Detroit ordinances prohibiting t operation of theaters showing sexually explicit "adult movies" within 1,000 feet of 1 two other adult establishments.9/ The ordinances authorized a waiver of the 1,0004 restriction if a proposed use would not be contrary to the public interest and/or oft factors were satisfied. Young, supra, 427 U.S. at 54 n.7, 96 S.Ct. at 2444 n.7. T • ordinances were supported by urban planners and real estate experts who testified tf concentration of adult-type establishments "tends to attract an undesirable quan: and quality of transients, adversely affects property values, causes an increase crime, especially prostitution, and encourages residents and businesses to mc elsewhere." Id. at 55, 96 S.Ct. at 2445. A "myriad" of locations were left available. adult.establishments outside the forbidden 1,000-foot distance zone, and no existi, establishments were affected. Id. at 71 n.35, 96 S.Ct. at 2453 n.35. i • - Writing for a plurality of four, Justice Stevens upheld the zoning ordinance as reasonable regulation of the place where adult films may be shown because (1) the was a factual basis for the city's conclusion that the ordinance would prevent blight; the ordinance was directed at preventing "secondary effects" of adult-establishme concentration rather than protecting citizens from unwanted "offensive" speech; (3) tt ordinance did not greatly restrict access to lawful speech, and (4) "the city must allowed a reasonable opportunity to experiment with solutions to admittedly seric, problems." Id. at 63 n.18, 71 nn.34, 35, 96 S. Ct. at 2448-49 n.18, 2452-53 nn.34, 35. 8/ The only reported Minnesota court case reviewing an adult entertainment zcnir ordinance is City of St. Paul v. Carlone, 419 N.W.2d 129 (Minn. Ct. App. 198, (upholding facial constitutionality of St. Paul ordinance). 9/ The ordinances also prohibited the location of an adult theaters within 500 feet of residential area, but this provision was invalidated by the district court, and the decision was not appealed. Young v. American Mini Theaters. Inc., 427 U.S. 50, n.2, 96 S.Ct. 2440, 2444 n.2 (1976). 1 -31-