Federal Judge Tosses Claim Over Strip Club Brochures

ATLANTIC CITY — New Jersey authorities are not civilly liable for an employee's decision to remove strip club brochures from Garden State Parkway service plazas, a federal judge ruled last week.

The operators of Bare Exposure sued defendants South Jersey Transportation Authority, New Jersey Turnpike Authority and the private service plaza operator HMS Toll Roads in 2012 on free speech and other grounds.

Bare Exposure said the defendants rejected its brochures, which depict a woman's face and the text "Bare Exposure ... Atlantic City's Only All Nude Entertainment."

A manager with HMS, which operates the plazas, ordered the brochures removed because he felt patrons would find them offensive.

The manager, Greg Dion, said he did not order the brochures removed for commercial reasons but admitted it could affect the club’s business.

Bare Exposure's amended complaint asserted a First Amendment violation and challenge to code provisions; 14th Amendment due process and equal protection violations; and speech, association, due process and equal protection violations of the New Jersey’s Constitution.

Bare Exposure moved to restrain the defendants from removing the brochures, and the defendants moved for summary judgment.

But U.S District Judge Renee Marie Bumb found that Dion acted on his own authority and not under the state's direction when she granted the defendants' request for a summary judgment.

"The undisputed facts make clear that Mr. Dion's decision to have the brochures removed was his and his alone; he did not consult with or receive any direction from the authorities," the judge said. "Moreover, he did not review or consider any provisions of the New Jersey Administrative Code prior to making his decision, but instead, he believed he was exercising Host's authority under the CTM agreement."

Bumb also tossed the claim that political pamphlets in the plazas support a state action.

"Plaintiff has presented no evidence beyond mere argument that such communications were 'done in such a manner that a reasonable patron would tend to assume that all the messages being presented were those of the respective authorities,'" Bumb wrote. "Such conclusory assertions are insufficient to survive summary judgment."

View ruling

Related:  

Copyright © 2026 Adnet Media. All Rights Reserved. XBIZ is a trademark of Adnet Media.
Reproduction in whole or in part in any form or medium without express written permission is prohibited.

More News

Eva Angelina Makes Her Tushy Debut

Eva Angelina has made her debut for Vixen Media Group studio imprint Tushy.

FSC Talks Age Verification on Capitol Hill

The Free Speech Coalition (FSC) has published a blog post detailing the organization's talks on age verification on Capitol Hill in Washington.

Catherine Knight, Dolly Dyson Star in Latest From Blacked Raw

Catherine Knight stars with Dolly Dyson in the latest release from Vixen Media Group studio imprint Blacked Raw.

FTC Warns PayPal, Stripe, Visa, Mastercard Against Debanking

Federal Trade Commission Chairman Andrew Ferguson sent letters on Thursday to the CEOs of PayPal, Stripe, Visa and Mastercard, warning them against debanking practices — including denying access to services due to a customer’s lawful business activities.

Brooke Tilli Makes Her Brazzers Debut

Brooke Tilli has made her Brazzers debut alongside studio exclusive Girthmasterr in "Who's In Charge Here!?"

EU Cites 4 Adult Sites for AV Breaches

The European Commission has preliminarily found PornHub, Stripchat, XNXX and XVideos to be in breach of Digital Services Act provisions intended to shield minors from adult content.

Alison Rey, Alexis Malone Lead Latest From Swappz

Alison Rey and Alexis Malone star in the latest release from Swappz's "MomSwap" series, titled “Four-Way 69 — The Hunting Moms.”

Abigaiil Morris Stars in Latest From Brazzers

Abigaiil Morris stars with Danny D in the latest release from Brazzers, titled "Cooking With Abigaiil."

Barbie Rous Is Hustler's 'Cover Honey' for April

Barbie Rous is the Cover Honey for the April issue of Hustler Magazine and appears in a 12-page centerfold spread shot by Davide Esposito.

Lovita Fate Returns to Immoral Productions

Lovita Fate stars in the latest trilogy from Immoral Productions, alongside Devils Kos, Terry Banks, and studio honcho “Porno Dan” Leal.

Show More