Supreme Court Ruling Adds Strings to Nude Dancing.

• Position: Brief Article

The U.S. Supreme Court's decision last year in City of Erie vs. Pap's A.M. may have far-reaching implications for cities and states that want to outlaw nude dancing. In Erie, the Court upheld a Pennsylvania ordinance that requires exotic dancers to wear g-strings and pasties while performing.

The Court determined that the ordinance was a content-neutral regulation of speech designed to deter the secondary effects of criminal activity associated with adult businesses, and that requiring dancers to wear minimal attire was the least restrictive way to meet that goal.

The Erie decision appears to add extra muscle to states' efforts to stringently regulate adult businesses.

Suddenly, "secondary effects" are first in line. Some states are already considering bills that may not ban nudity, but will place additional restrictions on adult businesses.

Twenty-two states considered bills last year to tighten their adult entertainment laws. Delaware passed a bill further restricting locations of adult businesses and added tax evasion as a reason to revoke the license of an adult business. Maine passed a law adding nude dancing to the list of dangerous occupations, and requiring all dancers to be at least 18 years of age. In May, Mississippi lawmakers approved a measure prohibiting strip clubs within a quarter mile of a church, school, kindergarten or courthouse.

Although the topic is receiving increased attention from legislators around the country, Kenneth A. Paulson, executive director of the...