In the case of Young, Mayor of Detroit, et al. v. American Mini Theatres, Inc., et al., 1975, the U.S Supreme Court upheld a zoning ordinance in Detroit that regulated locations for adult theaters and bookstores to prevent deterioration of neighborhoods. The plaintiffs were operators of adult movie theatres who argued that this law violated their First Amendment rights by discriminating against certain types of speech based on content (adult material). However, the court ruled in favor of the city with a 5-4 decision stating that while these businesses have not been banned or suppressed entirely from operating within city limits; they are merely dispersed so as to minimize negative impact on surrounding areas. This ruling established an important precedent allowing municipalities more control over local land use and regulation without infringing upon free speech rights.

In the dissenting opinion for Young, Mayor of Detroit, et al. v. American Mini Theatres, Inc., et al., Justice William Brennan Jr. argued that the First Amendment does not allow for different treatment of speech based on its content or subject matter. He disagreed with the majority's view that adult films are a form of 'low-value' speech and therefore can be subjected to greater regulation than other types of expression without violating constitutional protections. In his view, this approach undermines fundamental principles about freedom of expression by allowing government officials to decide what kinds of speech have value and which do not - something he believed was inherently dangerous and contrary to democratic ideals.