Golden Gate University Law Review


In Colacurcio v. City of Kent, the United States Court of Appeals for the Ninth Circuit held that the City of Kent's Ordinance 3221, which required nude dancers to perform at least ten feet from patrons, did not violate the First Amendment of the United States Constitution. The court found that, as a matter of law, the Kent ordinance was content-neutral and the ten-foot distance requirement was narrowly tailored and left open ample alternative avenues for communication of protected expression.