The U.S. Supreme Court case City of Renton et al. v. Playtime Theatres, Inc., et al., 1985 revolved around the First Amendment rights and zoning laws for adult theaters. In this case, Playtime Theatres sought to open an adult theater in Renton city but was denied due to a city ordinance that prohibited such establishments within 1,000 feet of any residential zone or within one mile of any school or park. Playtime Theatres sued on grounds that their First Amendment rights were being violated by these restrictions as they targeted the content of films shown at their establishment rather than its secondary effects (such as crime rates). However, the Supreme Court ruled in favor of Renton City with a majority decision stating that the ordinance did not violate free speech protections because it was aimed at reducing negative secondary effects associated with adult theaters rather than suppressing expression itself.

In the dissenting opinion for CITY OF RENTON et al. v. PLAYTIME THEATRES, INC., Justice William Brennan argued that the majority's decision to uphold Renton's zoning ordinance was a violation of First Amendment rights. He contended that by allowing cities to use zoning laws as a means of restricting adult theaters based on their content, it set a dangerous precedent for potential censorship and suppression of free speech in other contexts. Brennan also criticized the majority’s reliance on American Mini Theatres case which he believed was wrongly decided because it allowed government regulation based on content under guise of secondary effects doctrine without requiring evidence supporting such claims. He further noted that Renton had not provided any substantial evidence showing these theaters would have negative 'secondary' effects like increased crime or decreased property values, thus making its restrictions unjustified and unconstitutional.