The U.S. Supreme Court case City of Los Angeles v. Alameda Books, Inc., et al., 2001 revolved around a dispute over the First Amendment rights and zoning laws in relation to adult businesses. The city of Los Angeles had enacted an ordinance prohibiting multiple adult entertainment businesses from operating in the same building, based on a study suggesting that such establishments led to increased crime rates in their vicinity. Alameda Books and Highland Park Bookstore were two such businesses sharing premises who challenged this law as being unconstitutional under the First Amendment's free speech protections. In its decision, the Supreme Court held that it was not necessarily unconstitutional for cities to use zoning regulations to curtail concentrations of certain types of businesses if they could demonstrate a substantial government interest - here reducing crime - behind these restrictions. However, it also stated that there must be reasonable evidence supporting this claim; mere speculation would not suffice. The court did not definitively rule whether or not Los Angeles' specific ordinance met these criteria but instead sent back (remanded) the case for further consideration by lower courts with guidance about what kind of evidence is necessary.

In the dissenting opinion for City of Los Angeles v. Alameda Books, Inc., Justice Stevens argued that the city's ordinance was a form of content-based regulation and thus should be subject to strict scrutiny. He contended that there was no substantial evidence supporting the city's claim that reducing concentration of adult businesses would decrease crime rates in surrounding areas. Furthermore, he suggested that if such an association did exist, it could be due to factors unrelated to speech (such as increased late-night activity), which could be addressed through other means without infringing on First Amendment rights. In his view, by forcing businesses to separate their merchandise into different establishments based solely on its adult nature - even when they are not noticeably distinct from outside - the city is directly regulating speech because of its content rather than addressing secondary effects associated with these businesses.