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

Kazumi Partners With Rose in Good Faith to Release 'V-Mule' Vulva-Shaped Footwear

Multi-XMAs winner Kazumi has teamed up with fashion brand Rose in Good Faith to release V-Mule vulva-shaped footwear.

Another German Court Rejects Blocking Orders Against Pornhub, YouPorn

A German court has blocked the Rhineland-Palatinate Media Authority (MA RLP) from forcing telecom providers based within the court’s jurisdiction to cut off access to Aylo-owned adult sites Pornhub and YouPorn.

Cubbi Thompson Leads Latest From New Sensations

Cubbi Thompson stars with Codey Steele in the latest release from New Sensations.

Ofcom Fines Kick Online Entertainment $1 Million for AV Noncompliance

U.K. media regulator Ofcom on Thursday fined Kick Online Entertainment 800,000 pounds (more than $1 million) for failing to implement age checks as required for compliance with the Online Safety Act.

FSC Details Legislative Outlook for 2026

The Free Speech Coalition (FSC) has laid out the legislative outlook for the industry in 2026.

Gray Perrier, Liv Revamped & Zariah Aura Star in New Transfixed Release

Gray Perrier stars with Liv Revamped and Zariah Aura in the latest release from Transfixed, titled "Bachelorette Stripper Switcheroo."

Reptyle Debuts Cross-Site Release 'Mom vs. Girlfriend'

Reptyle is launching a cross-site release on its Family Strokes, MYLF, Freeuse, and TeamSkeet imprints, titled “Mom vs. Girlfriend.”

Judge Dismisses NCOSE-Backed Suits Against Adult Sites Over Kansas AV Law

A federal judge on Tuesday dismissed lawsuits brought against two adult websites in Kansas for alleged violations of the state’s age verification law.

Sara Jay Makes Her MILFY Debut

Sara Jay has made her debut for Vixen Media Group (VMG) studio imprint MILFY, alongside Hollywood Cash.

Show More