9th Circuit Upholds Adult Business Zoning Ordinance

SAN DIEGO — In a court ruling of enormous proportions, a federal appeals court has sided with San Diego County over an ordinance regulating the operation of adult entertainment businesses and requiring them to move to industrial zones.

The 9th U.S. Circuit Court of Appeals on Wednesday affirmed a lower court’s grant of summary judgment against Déjà Vu and its landlord on their claim that the ordinance violated a state law requiring ordinances to be consistent with a county’s general plan.

The 9th Circuit said that plaintiffs had failed to raise the claim in their complaint and that San Diego County’s ordinance is constitutional.

Jurists, however, reversed the lower court’s decision to sever the time period for reviewing permits under the ordinance because the decision raised other constitutional problems.

The San Diego County Board of Supervisors adopted a comprehensive zoning ordinance in June 2002 to regulate the operation of adult entertainment businesses within unincorporated portions of the county.

The law took effect the following month and restricted the hours in which businesses could operate, required the removal of doors on peep show booths, and mandated that the businesses disperse to industrial areas of the county.

Supervisors’ rationale was purportedly to combat negative secondary effects — crime, noise, disorderly conduct, blight, traffic, property value depreciation and unsanitary behavior — that concentrated in and around adult businesses.

Déjà Vu and its landlord Tollis Inc. initiated federal and state constitutional challenges against the ordinance in the district court, seeking declaratory and injunctive relief.

The 9th Circuit granted summary judgment to the county, upholding the requirement that adult establishments locate only in industrial zones and dismissing a claim that the ordinance violated state law requiring ordinances to be consistent with a county’s general plan.

The court, however, also found that the county’s permitting regime for adult establishments unconstitutionally granted the licensing body an unreasonably long period of time to consider permit requests, and severed the time limits from the ordinance.

Judge Barry G. Silverman, who wrote Wednesday’ ruling, rejected the plaintiff’s argument that the list of available sites did not allow them a reasonable opportunity to operate their business because the sites were zoned only for industrial — not commercial — use.

“So long as there are a sufficient number of suitable relocation sites,” Silverman wrote, “the county could reasonably assume that, given the draw of pornographic and sexually explicit speech, willing patrons would not be measurably discouraged by the inconvenience of having to travel to an industrial zone.”

“Whether or not an industrial zone permits generic commercial business within its borders rests on a legislative policy judgment. Asking whether an industrial zone is suitable for generic commercial activity examines the physical characteristics and infrastructure of the land within the zone,” he wrote.

The 9th Circuit has jurisdiction over courts in Alaska, Arizona, California, Hawaii, Idaho, Montan, Nevada, Oregon and Washington.

The case is Tollis Inc. vs. County of San Diego, No. 05-56300.

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

Orion Expands 'Beastly Cocks' Line

Orion Wholesale has introduced three pleasure products from its Beastly Cocks line.

Polish Government Proposes AV Mandate for Adult Sites

Poland’s Council of Ministers on Tuesday endorsed a proposed national law that would require sites and platforms to age-verify users to prevent minors from accessing adult content online.

Sliquid Launches B2B Portal 'Sliquid HQ'

Sliquid has launched Sliquid HQ, the company's new B2B portal centralizing its distribution, educational, and marketing resources.

Brazil Launches Complaints Page for AV Violations, Other Issues

Brazil’s National Data Protection Authority (ANPD) on Monday debuted a portal where citizens can report possible violations of the country’s Digital Statute for Children and Adolescents (Digital ECA), which requires adult websites to age-verify users located in Brazil.

COTR Taps Dr. Alix Agar for Advisory Board

COTR has appointed Dr. Alix Agar to its medical and therapeutic advisory board.

CC Wellness Names Melody Cazarin Director of Strategic Accounts

JO parent company CC Wellness has appointed Melody Cazarin to the position of director of strategic accounts.

Orion Expands Cottelli 'Bondage' Line

Orion Wholesale has added five new lingerie sets to its Cottelli Bondage collection.

Full Circle Expands 'Savage Me' Line of Strokers

Full Circle has expanded its line of Savage Me strokers.

XR Brands Debuts 'Scarlet Seduction' Travel Set From 'Master Series' Line

XR Brands has introduced the Scarlet Seduction Leather Bondage Travel Set from its Master Series collection.

Morari Debuts 'MOR' Male Enhancement Patch

Sexual wellness brand Morari, Inc. has launched its new male enhancement patch, MOR.

Show More