The Evidence of Relationships Between Adult-Oriented Businesses and Community Crime and Disorder
Posted by NPNAdmin at 5/27/2007 7:39 AM 
Categories: Impact of Porn,Ordinances and Regulations,Strip Clubs,Legal Strategies,Capital Video Corporation,Secondary Effects,Organized Crime,Debate on the Issues
Categories: Impact of Porn,Ordinances and Regulations,Strip Clubs,Legal Strategies,Capital Video Corporation,Secondary Effects,Organized Crime,Debate on the Issues
Some people deny that Capital Video's porn shop in Springfield (Amazing.net) is bringing prostitution to the Apremont Triangle neighborhood and retarding economic development there. Others cite a handful of studies to suggest that it is debatable whether adult enterprises impose a risk of secondary effects on their surroundings (e.g. crime, blight), ignoring the clear preponderance of the evidence that secondary effects are real and can have a major, long-term impact on communities.
The risk is akin to siting a toxic waste dump next to homes. Maybe your air and drinking water won't be poisoned, but the danger is hard to accept and the damage, when it occurs, hard to remediate (Blaine, WA: "years of frustration and community heartache for many local residents"). The solution in both cases is to locate the hazardous business away from residential areas.
Our opponents believe they are perceiving the Apremont Triangle situation more accurately than residents who live there, the police commissioner of Springfield, and the mayor of Springfield. They make vague claims that 'preexisting conditions', "corrupt politicians", or problems with "education", "housing conditions", "jobs" and "drugs" are to blame for Apremont Triangle's problems. These are all valid issues, but they don't let Amazing.net off the hook for the harms that can be traced to it, and they ignore evidence that "small things" matter in urban revitalization, as Rudy Giuliani famously demonstrated in New York City. It is not politicians, education or housing that repel sought-after grocery stores from locating in Apremont Triangle, it is Amazing.net, and the "crowd that you see around it."
In 1996, Ed Wassman, Chief of Police for St. Marys, Georgia, and Detective Lieutenant Dar Hendrickson gathered research on secondary effects for the mayor and city council. They verified that adult businesses impose a real, measurable risk of harm on their surroundings, justifying municipal regulation. We present excerpts from this report, and provide links to source documents where we can. We made minor adjustments to the formatting of the report to improve readability.
A DIGEST OF RESEARCH:
The Evidence of Relationships Between Adult-Oriented Businesses and Community Crime and Disorder
[See the complete report as a PDF]
...PRELIMINARIES, FOR THE RECORD:
My name is Ed Wassman, I have been your chief of police for nearly ten years. I have over thirty years of law enforcement experience, I hold both a bachelor’s and master’s degree in public administration, specializing in law enforcement administration. I am certified by the State of Georgia as both a police officer and a police executive. Furthermore, I am certified by the Southeast Association of Colleges and Schools (SACS) as a full adjunct professor of criminal justice with Georgia Military College and as an instructor of criminal justice with Troy State University.
And, also offered for the record:
I have been ably assisted in this research project by Detective Lieutenant Dar Hendrickson, a tenured criminal investigator with the St. Marys Police Department. Det. Lt. Hendrickson has over forty years of law enforcement experience, including a founding role with the Georgia Organized Crime Council. He holds a bachelor’s degree in criminal justice, and he is also SACS certified as an adjunct instructor of criminal justice with Georgia Military College.
OUR ASSIGNMENT:
We, at the police department, have been requested to gather research relating to evidence of the relationship between crime (including disorder) and adult-oriented businesses, if any. This phenomenon is also sometimes known as a pernicious secondary effect of adult-oriented businesses...
METHODOLOGIES NOTED IN STUDIES:
This extensive collection of social science research utilizes many different methodologies currently recognized by authorities who are well-versed in the elements of rational social scientific investigations. The imprecated structures include:
• community sampling and survey instruments,
• longitudinal and time population data analyses of empirical records,
• multivariate correlation analysis with controls,
• covert and overt observational studies, and;
• anecdotal and testimonial evidence.
These were all found to be relative to quantitative and/or qualitative queries into the negative or pernicious secondary effects of adult businesses on a community, if any. Ostensibly, for the purpose of this digest, we will not delve into the realm of social science research, design, instruments, or methodologies except to state that these studies--taken as a whole--provide the reader with three basic standards essential to make informed inferences and reasonable judgments of fact:
1. Where possible, identifiable and measurable quantitative variables are used;
2. the significance and chances that data about variables are meaningful is tested;
and,
3. the relationships between variables (association and correlation) with control variable testing is noted.
ABSTRACTS OF SPECIFIC STUDIES INCLUDED:
[NOTE: These abstracts have been prepared with the least amount of paraphrasing applied.]
1. State of Minnesota, Report of the Attorney General’s Working Group on the Regulation of Sexually Oriented Businesses, Office of the Attorney General (June 6, 1989):
This is a seminal work which investigates the secondary effects of adult businesses from a number of different research perspectives. Not only is the effect on crime included, so is the effect on neighborhood disorganization and disorder, as are the effects on property values addressed. The New York study also concluded that business locations with adult-oriented businesses had a significant loss of sales tax collections (42%) as compared to control areas. Studies of Minneapolis, St. Paul, Indianapolis, Phoenix, and Los Angeles are cited. RICO and organized criminal elements of the industry are also discussed. It was found that dramatic increases in crime rates were directly associated with the introduction of adult-oriented businesses into any community studied. Evidence is articulated indicating that property crimes were forty to fifty percent higher, and sex-related crimes were found to be seventy to as much as 500 percent higher--depending upon the municipality. Other non-crime community issues are also discussed.
2. Final Report to the City of Garden Grove: The Relationship Between Crime and Adult Business Operations on Garden Grove Boulevard, City of Garden Grove, California, (October 23, 1991):
This study included such crime related questions as, “Does crime increase in the vicinity of an adult business? If so, is the increase statistically significant and does it constitute a public safety hazard?” Extensive statistical analysis is applied to ten years of reported crime data (1981-90).The analysis shows that crime rises whenever an adult business opens or expands its operations and, the change is statistically significant. This is found when comparing three address-specific sites with control sites. A consistent pattern is found demonstrating that the adult businesses are indeed a public safety hazard. Notably, when adult businesses open within 1000 feet of a tavern (or vice versa), the impact of the adult business on crime is further aggravated substantially and significantly. Results of survey data show that residents who live near adult businesses, as well as those who live farther away, associate adult businesses with increased crime and other negative impacts on the quality of the neighborhood. Many women respondents expressed an overwhelming fear for their safety and the safety of their children. More than one in five respondents reported a specific negative or criminal incident related to the operation of adult businesses. Although the opinion surveys may represent subjective option, their results are consistent with objective analysis of crime data. Other non-crime community issues are also discussed.
3. Relationship of Criminal Activity and Adult Businesses, Planning Department, City of Phoenix Arizona, (May 1979):
This report expounded on two basic hypotheses. First, that there are direct impacts which uniquely relate to this class of land use; and second, that there are indirect, but equally potent, attitudinal concerns which result from proximity to adult businesses. This study specifically shows that there is a higher amount of sex offenses committed in neighborhoods containing adult businesses as opposed to those without them. Control areas were utilized in the design. The study postulates that there appears to be a significantly greater difference between the study area (those with adult businesses) and the control areas (those without) for sex crimes than for either property or violent crimes. They report an increase of about forty percent in property crimes, about four percent in violent crimes, and 606 percent in sex-related crimes. Other non-crime community issues are also discussed.
4. A Study of Crime and Adult Entertainment, Police Department Memorandum, City of Tucson, Arizona, (May 11, 1990):
[A Caveat: If you are not accustomed to criminal justice studies of explicit alternative and criminal sexual behavior, please approach the parent study document with caution.]
In sum, a covert observational study. Investigating officers found that many of employees of the adult-oriented businesses were prostitutes who were offering private shows where customers could, for a price, observe them performing live sex acts. For “the right price” customers would be allowed to “touch the dancers.” Undercover operatives also learned that customers could hire the dancers to engage in acts of prostitution, and in some instances, these acts actually occurred on the premises with the knowledge of the management. Underage females were also being hired to dance nude. The report also confirmed many health-related perspectives: Adult entertainment establishments provide an environment and atmosphere that is conducive to high risk sexual behaviors and practices with respect to sexually transmitted diseases (HIV and hepatitis B included).
5. Report to the Rome City Commission--Adult Entertainment, Police Department, City of Rome, Georgia, (March 6, 1995) (PDF):
This report includes crime data from the city of La Grange, Georgia. La Grange is more like St. Marys than different. Located in that small suburb of Atlanta, is a three-year-old “adult nightclub.” In just one year (1994) that single adult-oriented nightclub generated 141 calls-for-service, with thirty-five of those calls being criminal in nature. Those crimes included such violent crimes as: eight criminal batteries and eight aggravated assaults (knives, baseball bats, and firearms with shots fired). The report also includes many of the other municipal studies articulated elsewhere in this digest.
6. Report of the Troup County Planning Commission, Troup County Planning Commission, Troup County, Georgia, (an undated report by Mr. Rick Morris, MPA):
Among other topics, this report cites the Austin, Texas study. The Austin study revealed that crime rates were higher than the city average, and that sex related crimes were two to five times higher than the city-wide averages. Other non-crime community issues are also discussed.
7. Report by the Chatham County-Savannah Metropolitan Planning Commission, Chatham County Board of Commissioners, Mr. Howard Bellinger, Executive Director, Savannah, Georgia, (September 24, 1993)...
The County Commissioners requested an evaluation of the need to better regulate adult entertainment uses and determine and recommend what type of zoning standards would be desirable to regulate these uses in order to protect adjacent or area properties from the secondary effects created by such uses. Within their summary of materials researched they concluded that--from their staff’s review of the studies--their staff need not repeat the detailed study efforts in order to determine the secondary effects of adult entertainment business on a community. Both crime and property values are negatively [affected]. They cite a Manatee County, Florida, Planning and Development Department study, “Adult Entertainment Business Study for Manatee County” completed in June of 1987.
8. Report of the Chief of Police and Covert Investigation to City Attorney, Mayor and Council of the City of College Park, College Park, Georgia, (March 14 and 25, 1996):
[A Caveat: If you are not accustomed to criminal justice studies of explicit alternative or criminal sexual behavior, please approach the parent document with caution. Furthermore, this report is supported by a covert police operation that is CONFIDENTIAL in nature.]
Chief G.J. Bencale stated that his police department’s undercover officers completed a covert investigation as part of their fact finding effort. Lingerie modeling is basically masturbation for hire (a criminal offense). Officer Bedford said they went to lingerie modeling businesses in the Atlanta and Columbus area. Chief Bencale said they had an overall increase in sex crimes including incidents where dancers were raped, as well as an increase in drugs, theft, and etc. These businesses attract criminal activity. Chief Bencale also stated that some cases involved organized crime. Detective Sergeant Tom Kunzniacki stated that--from a law enforcement standpoint--it would be difficult to enforce criminal violations without the undercover officer committing illegal and unethical acts, and undercover operations to check for compliance with the law and codes would be expensive. Observations were also made about organized crime, money laundering, and drugs. Arrest reports from the City of Columbus, Georgia, Police Department were entered as evidence of criminal activity in such a business--criminal charges included: Masturbation for Hire, Disorderly Conduct, Sexual Exploitation of Children, Solicitation for Sodomy, and Prostitution.
9. Ordinance, City of Smyrna, Georgia (September 1990):
Several follow-up contacts were made to include their “evidence,” however, we only received their ordinance and a copy of a license application. The preamble of the ordinance does state that the City of Smyrna finds that adult entertainment establishments, if unregulated, will likely lead to an increase in prostitution, venereal disease, drug and alcohol offenses and other criminal activity…adult entertainment establishments sometimes are fronts for or operated by persons associated with organized criminal activities and the need to scrutinize such dance establishments…the law enforcement resources available for responding to problems associated with or created by adult entertainment establishments are limited and are best conserved by regulating and licensing adult entertainment establishments and those associated with them.
10. Ordinance and Support Documents, City of Jacksonville, Florida (March 1995):
The City of Jacksonville, Florida (Duval County) has provided a compete text of their very comprehensive adult-entertainment ordinance. Included, of significant interest, is a support document from the City of Seattle (Department of Construction and Land Use, March 24, 1989). Testimony taken in Seattle included concerns and fears about these businesses in their neighborhoods. Problems with parking and traffic, attraction of transients, increases in crime, (and) hazards for children and personal safety. This document also included studies from New York, Cleveland, Indianapolis, Los Angeles, Austin, Phoenix, and Boston. They observed that, while not every adult business is predisposed to be involved with criminal activity there is enough documentation, as evidenced in the studies, to demonstrate a direct link between the potential for increased criminal activity and adult cabarets.
INTERESTINGLY, they note the “consumer trade characteristics” studies in Bothell, Washington, and Austin, Texas, confirm that at least one half of all customers frequenting adult businesses resided outside the city limits. They further stated that, people who patronize these establishments may have no sense of identity with or regard for the neighborhood in which these businesses may be located and, therefore, are less inhibited in their personal behavior than if they were in their own community.
Additional secondary effects of police calls to a business are also cited: Noise from sirens and flashing lights, and traffic hazards from police and emergency vehicles are disturbances not conducive to healthy business or residential environments. The increased potential for crime, together with these additional secondary effects, result in increased impacts which are more substantial than those of other neighborhood commercial uses which are intended to serve the needs of surrounding residents.
Also included in the City of Jacksonville documents are excerpts from letters to Don Wildmon (Editor) at the American Family Association. One letter from an inmate--convicted in the murder of four people--said, in part, ”I began frequenting topless discos, X-rated movie houses and massage parlors. I had many sexual encounters with prostitutes during this time, and on several occasions, I engaged in sexual acts which I’m too ashamed to talk about... In 1975 I went on a crime spree during which I had a major part in brutally murdering four innocent people. I’m now serving life in prison... While I am personally responsible for the crimes I committed, pornography helped bring me to the point where I didn’t care any more and thus enabled me to slip to the point where I was actually a participant in four bloody murders.”
Also included is a City of Oklahoma City, Community Development Department, Planning Division 1986 Survey of Real Estate Appraisers. This survey summarized opinions, to include: a threat to residents feeling of safety and security; problems with parking, trash, and debris; increased vandalism; and the fear that children in the area would be in danger of adverse influences or actual molestation by people drawn to such establishments...
THE EVIDENCE, RELATIONSHIPS, AND OUR COMMUNITY:
There are many inferences associated with adult-oriented businesses and crime, disorder, or public safety “hot spots,” the dangers of drugs, money laundering and, indeed, organized crime. While one might not suspect that drugs, money laundering, and organized crime may become a major problem in St. Marys and, while we can not discuss on-going covert investigations, we do respectfully suggest the following general comments for consideration.
The term “organized crime” conjures up visions of “the Mafia,” “la Cosa Nostra,” “bootleg booze,” “prostitution,” “gambling,” and a host of other criminal activities associated with the past involvement of truly “organized crime families.” The break-up of many of the more prominent “families” i.e., Bonnano, Accardo, [Genovese], etc., may give rise to the false supposition that organized crime is no longer a threat to be dealt with. The faces and the names may change; but, in a market economy, organized criminal activity will remain. Only their game plan changes. The massive and unrelenting influx of illicit drugs and the tremendous amount of money involved in the traffic of these drugs has dictated the need to find a new, legitimate-on-its-face, means of converting and concealing the illicit profits derived from the drug trade. As street-level transactions continue to funnel funds into the coffers of the major players, it becomes necessary for them to find or create false business fronts through which to launder the illicit funds and divert them back into the legitimate economy in such a manner that they cannot be traced to the drug trade.
Among the “cash-friendly,” service-type businesses are the adult-oriented businesses. This type of business is a ready avenue to be utilized in converting illegal cash into legitimate cash. Although much of the money laundering will take place through outlets in the larger metro areas, it stands to reason that a diversification (or franchised) of these adult-oriented outlets into the suburban and the smaller rural towns areas will make the paper trail even more difficult to follow and also more difficult for law enforcement agencies to prosecute.
These types of public safety and criminal justice issues are coming; the only question is where and when. Local governments and criminal justice agencies need to be ever more vigilant in the identification and prosecution of this type of covert, organized, criminal activity.
The Evidence in Sum:
Currently, and as strictly defined, there are no adult-oriented businesses in the City of St. Marys--some “lingerie shows” and “male reviews” at area alcohol vendors have reportedly nudged the commonly used definitions. We can not, therefore, measure a local relationship between disorder or crime and adult-oriented businesses. If, however, we logically assume that these studies can be rationally transported across artificial municipal boundaries, we may be able to draw certain inferences in attempting to predict or rationally model, in relative terms, the consequences or, indeed, the collateral effects of adult-oriented businesses on our local crime data...
IN CONCLUSION:
It is our professional opinion, after reviewing all the studies cited and, taken as a whole, that there is a very substantial and highly credible body of evidence of increased criminal activity with relation to adult-oriented businesses and, especially with respect to sex-related crimes and, a bounty of opportunities for the organized criminal element. Moreover, one study specifically addresses an observed and measured aspect, inclusive of these negative relationships: a more profound impact on crime rates when the serving of alcohol is introduced into the variables and the analysis. As stated earlier, these types of businesses, with all their associated negative impacts to public safety and criminal justice are coming; the only question is where and when...
Lawful, proactive REGULATION is our community’s only line of defense in maintaining law and order, and, indeed, the continued quality-of-life and welfare of the community-as-a-whole.
See also:
Secondary Effects Across America: 1977-1999
Indianapolis: From 1978-82, crime increases in the study areas were 23 percent higher than the control areas (46 percent higher than the city as a whole). Sex-related crimes in the study areas increased more than 20 percent over the control areas. Residential locations in the study areas had a 56 percent greater crime increase than commercial study areas. Sex-related crimes were four times more common in residential study areas than commercial study areas with sexually oriented businesses.
The Case for Secondary Effects
Both Congressman Barney Frank and State Senator Stanley Rosenberg are comfortable with using zoning to mitigate secondary effects. These politicians respect First Amendment rights, while understanding that some modest regulation is warranted to meet citizens’ legitimate concerns...
All over the country, in many times and places, the people have shown that they can employ adult-use zoning responsibly to mitigate secondary effects without straying into general censorship. We are confident the people of Northampton will be equally wise.
New York City Planners Document Secondary Effects of Adult Uses, Support Zoning
"Of 100 businesses surveyed [in the Manhattan neighborhood of Chelsea], 61 percent felt that the triple-X video stores had a negative impact on their businesses and 88 percent thought the potential for doing business in Chelsea has been negatively affected by the adult stores...
"Those citing negative impacts from adult establishments [at a 1993 public hearing in Manhattan] noted crime most frequently, and quality of life impacts such as littering, noise, late night operations, offensive signage, and general perceptions about neighborhoods or certain streets...
"In surveys of community organizations, more than 80 percent responded that adult entertainment establishments negatively impact the community in some way...
"The experience of urban planners and real estate appraisers indicates that negative perceptions associated with an area can lead to disinvestment in residential neighborhoods and a tendency to shun shopping streets where unsavory activities are occurring, leading to economic decline...
"The strongest negative reactions to adult entertainment uses comes from residents living near them...
Understanding and Preventing Violence, Volume 3: Social Influences (1994)
...Sherman et al.'s (1989) finding that relatively few "hot spots'' produce a large proportion of predatory crime. Indeed, Sherman et al. (1989:39) found that all robberies and rapes in Minneapolis during 1986 occurred at less than 3 percent of "places," particularly bars, parks, adult bookstores, and convenience stores.
How the People Reclaimed Oklahoma City from a Major Eruption of Adult Businesses and Crime
[A good example of how adult enterprises can proliferate and cause problems during a time of prosperity. You can't blame preexisting blight here.]
Oklahoma City is a city of over 650 square miles within city limits with an MSA population [of] nearly 750,000. In the early 1980's Oklahoma City had a disporportionately large number of "Adult Oriented businesses". The economy of the '80s, in Oklahoma, helped pave the way for these businesses to thrive. The oil industry was in peak production and with massive exploration and production [the] state's population grew with an influx of oil field workers and support personnel. The salaries paid were often far above the national average in like industries and entertainment businesses grew rapidly in a symbiotic relation to the oil boom...
By [1984] [t]here were over 150 adult businesses operating in the city and an estimated population of 200 street prostitutes. The street offered their wares in half a dozen locations inside city limits and the crime rates in these areas skyrocketed. These areas came to be known as "strolls". Competition for a share in the profits to be made from adult businesses [led] the owners to become increasingly more blatant with street signs and advertisements...
Media involvement played an essential role in the plan to decrease the prostitution problems... Television media accompanying police on raids and filming from inside surveillance vans was unprecedented and the media's attention to the situation increased public awareness further. Citizen support grew from a more enlightened public. Community tolerance of adult enterprises turned to outrage and unilateral support for police and prosecutors in enforcement of "victimless" crimes for the first time.
Springfield Citizens Beat Back an Expansion of Their Capital Video Porn Shop (2002)
State Rep. Cheryl A. Rivera, D-Springfield, said yesterday that she...is calling councilors to express her opposition. She said she has received calls from constituents of Mattoon and Salem streets opposing the expansion. Rivera opposes the permit request, saying that it is an inappropriate use for a residential area. Some of the store's clients, she said, use the booths as a place to masturbate while watching adult movies and videotapes...
Councilors and residents said...[e]xpansion of an adult video store, along with additional private booths for customers to view movies, would...take away from efforts to bring more professional people to the downtown and further investment, they said. "This would not be a step forward--it would be a step back..."
NPNAdmin comment of 3/23/07, relating to Capital Video's porn shop in Springfield (Amazing.net)
When citizens feel that a city can't or won't deal with obvious nuisances like Capital Video's porn shop, it is understandable that they would feel despair. Despair is another important part of Springfield's problems.
[Dianne Little:] And this is all two blocks from the police station. I call that blatant. When you're trying to develop a nice neighborhood, rent a nice building, and you have to walk through a couple hookers to get in the door, or you're afraid you're going to be solicited on the way out...As Rudy Giuliani understood well, small things matter. You have to start somewhere. Shutting down Capital Video's porn shop in Springfield as a public nuisance would be an unmistakable signal that the city has the will and the ability to care for its residents.
[Springfield Police Commissioner Edward] Flynn said he frequently encounters a "culture of victimization, defeat and bitterness" that is slowing progress in Springfield.
"I understand it on one level," Flynn said. "On the other hand, it's a corrosive cancer."
Prosperous Minneapolis Commercial Area Blighted by Proliferation of Adult Enterprises
The adult bookstores and theaters which now line Lake Street have indelibly marked the character of the business community. Once a prosperous commercial area, East Lake Street now is characterized by decline and deterioration. Many legitimate businesses have moved out of the neighborhood and new ones have not replaced them. Business owners are frightened by the real possibility of business failure. When women do not feel safe on the streets, they will not come to the stores to shop. Legitimate businesses do not want to subject their employees, especially women employees, to harassment from the customers of the adult bookstores and theaters.
People in this neighborhood are demoralized and increasingly cynical about the fairness of the political process and of the legal system itself.
Journal of Planning Literature: Adult Bookstores Often Increase Fear of Crime, Discourage Walking
The land uses that line up a street or surround a public space are crucial for their safety. Abandoned buildings, liquor stores, seedy motels, bars, check-cashing establishments, pawnshops, and adult bookstores and movie theaters can generate crime because they can encourage antisocial behavior, concentrate lucrative targets, and attract potential criminals (Spelman 1993; Block and Block 1995). Such uses often give a neighborhood a bad reputation and increase the fear of crime. These bad neighbors should be banned from the vicinity of parks, bus stops, and public spaces.
State Land-Use Planner: "Once the 'use' is located in your community, it's very difficult to get rid of them"
"My general message is that once the 'use' is located in your community, it's very difficult to get rid of them," said Donald J. Schmidt, principal land-use planner for the state Executive Office of Communities and Development...
"If communities take time now to look at their zoning regulations, you can really lessen the impact dramatically so (an adult-entertainment business) doesn't pop up next to a high school, church or day-care center, to use those as examples," he said.
US Fifth Circuit Appeals Court Affirms that Evidence of Secondary Effects of "Off-Site Consumption" Adult Enterprises Is Sufficient To Justify Zoning
Kennedale’s ordinances purport to protect against harmful secondary effects. The Indianapolis and Oklahoma City studies support the belief that off-site sexually oriented businesses cause harmful secondary effects to the surrounding area in the form of decreased property value. So long as they are not relying on shoddy data or reasoning, we afford substantial deference to cities with regards to the ordinances they enact. See Alameda Books, 535 U.S. at 451 (Kennedy, J., concurring) (noting that “a city must have latitude to experiment” and “courts should not be in the business of second-guessing fact-bound empirical assessments of city planners”). The Indianapolis survey, in particular, was drafted by experts, pretested, and administered to a large, national pool of respondents. It is not “shoddy.” We therefore find that Kennedale has produced evidence that it could have reasonably believed was relevant, and thus could have properly relied upon. The ordinances are narrowly tailored to advance a substantial governmental interest...
Porn Merchant Implies: Host Community Put at Risk So Outsiders Might Enjoy Themselves
"We'll be helping the community, maybe not Berlin, but surrounding communities," [VIP general manager Gary] Porter said jokingly, "community service is what we're all about."
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