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Dills v. Cobb County, Ga.

Citation: 593 F. Supp. 170Docket: C83-1837A, C84-0324A

Court: District Court, N.D. Georgia; August 17, 1984; Federal District Court

Narrative Opinion Summary

In a consolidated legal action, plaintiffs challenge a Cobb County, Georgia sign ordinance that restricts the placement of portable signs, arguing that it violates the First Amendment, Equal Protection Clause, and Due Process Clause. The plaintiffs contend that the ordinance's setback requirements render portable signs ineffective, essentially amounting to a ban. Cobb County defends its ordinance as a content-neutral measure aimed at promoting traffic safety and enhancing the county's aesthetics. However, the court determines that the ordinance fails to substantiate its safety and aesthetic claims with concrete evidence, relying instead on unsupported testimonials. Citing the Supreme Court's standard from *Members of the City Council of the City of Los Angeles v. Taxpayers for Vincent*, the court concludes that the ordinance does not advance significant governmental interests without undue restriction on free speech. Consequently, the ordinance is deemed unconstitutional. A permanent injunction is granted against its enforcement, with the court finding no justification to delay judgment under Fed. R. Civ. P. 54(b). The court emphasizes that the ordinance's provisions disproportionately impact the plaintiffs' First Amendment rights, rendering further claims unnecessary.

Legal Issues Addressed

Aesthetic Justification in Sign Regulation

Application: The ordinance's aesthetic justifications are insufficient as the County does not demonstrate that portable signs are aesthetically displeasing compared to permanent signs.

Reasoning: The Court observes that the same sign can be deemed acceptable if permanently affixed but prohibited if temporarily placed, highlighting a lack of rationality in this classification.

Content-Neutral Regulation

Application: The ordinance is assessed as a content-neutral regulation, which applies to both commercial and non-commercial speech, thus not requiring differentiation between the two.

Reasoning: The court notes that the ordinance is content-neutral, applying to both commercial and non-commercial speech, thus eliminating the need to differentiate between the two types of expression in this context.

First Amendment and Sign Ordinances

Application: The court evaluates if the sign ordinance is a permissible regulation under the First Amendment, focusing on content neutrality and the ordinance's impact on free speech.

Reasoning: The plaintiffs assert that the ordinance violates the First Amendment, Equal Protection Clause, and Due Process Clause, claiming it significantly limits their ability to use portable signs effectively.

Governmental Interests in Sign Ordinances

Application: The ordinance's justification rests on advancing significant governmental interests such as traffic safety and aesthetics, which the County fails to substantiate with concrete evidence.

Reasoning: Traffic safety and aesthetics are recognized substantial governmental interests. The County argues that portable signs pose safety hazards and distract motorists, but fails to provide concrete evidence linking portable signs to accidents or injuries.

Injunction Against Ordinance Enforcement

Application: The court grants a permanent injunction against the ordinance, finding that the plaintiffs would suffer irreparable harm without it and that public interest favors its issuance.

Reasoning: The plaintiffs have met the criteria for injunctive relief, demonstrating that they would suffer irreparable harm without the injunction and that the public interest favors its issuance.

Unconstitutionality of Sign Ordinance

Application: The court finds the ordinance unconstitutional for failing to justify its restrictions on First Amendment rights with sufficient evidence of safety and aesthetic concerns.

Reasoning: Ultimately, the ordinance is deemed unconstitutional for failing to justify its restrictions on First Amendment rights based on traffic safety claims.

Vagueness in Legal Definitions

Application: The ordinance's definition of portable signs as temporary raises constitutional concerns due to its vagueness, affecting enforcement clarity for sign owners.

Reasoning: Additionally, the definition of a portable sign is problematic, as it includes any sign intended to be temporary, which could require even permanently affixed signs to be treated as portable if the owner plans to move them.