Young v. American Mini Theatres, Inc. 427 U.S. 50 (1976) Detroit adopted a zoning ordinance that regulated 'adult' theaters, limiting where they could be built. The idea was to not let a bunch of unsavory businesses congregate in the same neighborhood, thereby creating a 'skid row'. American challenged the ordinance, claiming that it was an unconstitutional infringement of their 1st Amendment right to free speech. American showed movies that were dirty, but were not considered obscene, and thus protected by the 1st Amendment. The Trial Court upheld the ordinance. American appealed. The Appellate Court reversed and overturned the ordinance. Detroit appealed. The Appellate Court found that the ordinance amounted to prior restraint of free speech, and that is almost never constitutionally permissible. The US Supreme Court reversed and found the ordinance to be constitutional. The US Supreme Court found that the ordinance didn't prevent American from showing movies, it only regulated where they could show them. Even regular movie theaters required a license and couldn't be built in areas zoned as residential. The Court found that this sort of speech was low-value speech, and as such didn't merit full 1st Amendment protections. The Court balanced American's right of free speech with Detroit's compelling interest to protect its citizens quality of life and found that the ordinance was constitutional. Until this case, speech was considered either fully-protected, or not protected at all. This case created a sliding scale where speech that was dirty yet not quite obscene received a lesser amount of protection under the 1st Amendment.