Cohen v. City of Daleville, Ala.

695 F. Supp. 1168, 1988 U.S. Dist. LEXIS 10463, 1988 WL 97344
CourtDistrict Court, M.D. Alabama
DecidedAugust 4, 1988
DocketCiv. A. 87-T-914-S
StatusPublished
Cited by3 cases

This text of 695 F. Supp. 1168 (Cohen v. City of Daleville, Ala.) is published on Counsel Stack Legal Research, covering District Court, M.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cohen v. City of Daleville, Ala., 695 F. Supp. 1168, 1988 U.S. Dist. LEXIS 10463, 1988 WL 97344 (M.D. Ala. 1988).

Opinion

MEMORANDUM OPINION

MYRON H. THOMPSON, District Judge.

Plaintiff Jerome Cohen, a public purvey- or of sexually explicit videotapes in Dale-ville, Alabama, has brought this lawsuit under 42 U.S.C.A. § 1983, charging that the city’s recent decision to revoke his business license constitutes a ‘prior restraint,’ in violation of the first amendment to the United States Constitution. Cohen has sued the City of Daleville, its mayor, and the members of its city council. Based on evidence presented at a nonjury trial, the court concludes that the city’s decision constitutes an impermissible prior restraint and that Cohen is therefore entitled to appropriate relief.

I.

Jerome Cohen, doing business as “Video World” and “Daleville Thrift and Pawn,” sells and rents videotapes, ranging from children’s and family films to sexually explicit ‘adult’ ones. His trouble with the law began in 1981, when he was convicted of distributing obscene literature. Later, in 1985, Cohen was caught with more allegedly obscene literature, but he disposed of the materials after the chief of police ordered him to do so.

Most recently, in February 1987, Cohen was arrested a second time for distributing obscene works. The authorities confiscated numerous sexually explicit videotapes and one “rubber simulated vagina.” The seized films were behind the counter, where they were out of public view, but the cardboard packages in which they came *1170 were on display for patrons to observe. It was clear that the videotapes had been rented out to customers. The artificial vagina was found in a cabinet behind a desk in the corner of the store. The authorities found no proof that the artificial vagina had been used for commercial purposes.

On June 9,1987, Cohen pleaded guilty to displaying, selling and distributing obscene videotapes. The charge was a misdemean- or, and he paid a $1000.00 fine. He was never charged with any offense for possessing the artificial vagina. Cohen’s problems did not end, however. Two months later, on August 4, the Daleville City Council notified Cohen that it was going to conduct a public hearing with respect to the issue of revoking his business license. 1

At the hearing, conducted on August 18, the city's attorney presented evidence recounting the events leading up to Cohen’s arrest and conviction. The attorney also presented, and the city council viewed, selected samples from the sexually explicit videotapes the police seized from Cohen’s business. 2 Cohen, however, rejected the city’s offer to put on evidence. His attorney simply stated to the council members that, if they decided to revoke Cohen’s license, their actions would constitute an impermissible prior restraint, and that Cohen would most certainly challenge their decision and seek damages in a court of law.

A week later, on August 25, the city council issued a statement finding that Cohen had conducted his business both immorally and illegally, and ordering that Cohen’s business license be revoked for 90 days, at which time Cohen could reapply for his license. More specifically, the council found that Cohen had conducted his business in a manner “detrimental to the public morals,” so as “to constitute a nuisance”; the council also found that he had operated his business “in an illegal manner as evidenced by [his] ... plea of guilt ... to criminal charges arising from [his] activities on [his] Business premises.” The council indicated that the revocation would not take effect until September 15, 1987, and would be stayed pending final resolution of any lawsuit should Cohen seek judicial review before that date.

On September 14 Cohen filed this action for injunctive and other relief, and thereby stayed the effective date of the revocation. He complained that the city’s action was an unconstitutional prior restraint on his freedom of speech. 3 The city denies that its *1171 action constitutes a prior restraint, contending instead that it lawfully punished Cohen for past criminal conduct.

II.

The doctrine of prior restraint provides, in general, that, except in very limited and specific circumstances, the government may not restrain a particular expression prior to its dissemination even though the expression may be obscene or otherwise be not constitutionally protected and thus subject to punishment after dissemination. Southeastern Promotions, Ltd. v. Conrad, 420 U.S. 546, 95 S.Ct. 1239, 43 L.Ed.2d 448 (1975); Bantam Books, Inc. v. Sullivan, 372 U.S. 58, 83 S.Ct. 631, 9 L.Ed.2d 584 (1963); Near v. Minnesota, ex rel. Olson, 283 U.S. 697, 51 S.Ct. 625, 75 L.Ed. 1357 (1931). The theory behind this doctrine is “deeply etched in our law: a free society prefers to punish the few who abuse rights of speech after they break the law than to throttle them and all others beforehand. It is always difficult to know in advance what an individual will say, and the line between legitimate and illegitimate speech is often so finely drawn that the risks of freewheeling censorship are formidable.” Southeastern Promotions, Ltd., 420 U.S. at 559, 95 S.Ct. at 1246-47 (emphasis in original). The parties agree that none of the limited circumstances is present here and that this case thus turns on the narrow issue of whether the Dale-ville City Council’s action constitutes a pri- or restraint.

A.

As a preliminary matter, the court rejects the City of Daleville’s contention that abstention is appropriate in this case. Abstention remains the “exception rather than the rule,” particularly in first amendment cases. City of Houston v. Hill, — U.S. -, -, 107 S.Ct. 2502, 2512-13, 96 L.Ed.2d 398 (1987). This case does not fall within any recognized exception. Abstention under Younger v. Harris, 401 U.S. 37, 91 S.Ct. 746, 27 L.Ed.2d 669 (1971), is not appropriate because state judicial proceedings are not pending. Hawaii Housing Authority v. Midkiff, 467 U.S. 229, 237-39, 104 S.Ct. 2321, 2327-28, 81 L.Ed.2d 186 (1984); Middlesex County Ethics Comm. v. Garden State Bar Ass’n, 457 U.S. 423, 432-34, 102 S.Ct. 2515, 2521-22, 73 L.Ed.2d 116 (1982); Fair Assessment in Real Estate Ass’n, Inc. v. McNary, 454 U.S. 100, 112-13, 102 S.Ct. 177, 184-85, 70 L.Ed.2d 271 (1981). Abstention under Railroad Comm’n v. Pullman Co., 312 U.S. 496, 61 S.Ct. 643, 85 L.Ed.

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Bluebook (online)
695 F. Supp. 1168, 1988 U.S. Dist. LEXIS 10463, 1988 WL 97344, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cohen-v-city-of-daleville-ala-almd-1988.