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

Cami Strella, River Lynn Front Latest From New Sensations

Cami Strella and River Lynn star in the latest release from New Sensations.

Vixen Drops Cross-Site Feature 'Pull'

Vixen Media Group has released “Pull,” a five-part, cross-site feature with scenes presented by its studio websites Vixen, Blacked, and Tushy.

Private Releases 'Private Gangbangs 5'

Private has released “Private Gangbangs 5,” directed by Xavi Rocka.

FTC Promises 'Vigorous' TAKE IT DOWN Act Enforcement

The Federal Trade Commission is warning platforms that the agency will strongly enforce the notice-and-removal requirements of the TAKE IT DOWN Act, which go into effect next week on May 19.

Adult Time, AgentRedGirl Release 3rd Installment of 'Oopsie! Animated'

Adult Time has released the third episode of "Oopsie! Animated," a limited futanari-themed series produced in collaboration with animation studio AgentRedGirl.

Zariah Aura, Rebel Rhyder Lead Latest From Evil Angel

Zariah Aura and Rebel Rhyder star in the latest release from Evil Angel, directed by multi-XMAs winner Aiden Starr.

2026 XBIZ Miami Speaker, Open-Floor Conversation Guide Lineup Announced

XBIZ is pleased to announce the release of the full speaker lineup for XBIZ Miami, the latest edition of the adult industry’s premier summer conference, set to take place May 11-14 at the Goodtime Hotel in Miami Beach.

Bad Bella Stars in Latest From New Sensations

Bad Bella stars with Alex Legend in the latest release from New Sensations.

Domino Presley, Chris Epic Front New Release from Grooby

Domino Presley and Chris Epic star in the latest release from Grooby Girls, titled “Cleaning the Pipes.”

McKenzie Mae Leads Latest From Family Strokes

McKenzie Mae stars with Joshua Lewis in the latest release from Family Strokes.

Show More