City of Dallas v. Stanglin
1989 U.S. LEXIS 1751, 490 U.S. 19, 104 L. Ed. 2d 18 (1989)
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Rule of Law:
The First Amendment's freedom of association does not protect generalized social interactions, such as recreational dancing among strangers in a public dance hall. Therefore, a government ordinance regulating such activity is subject to rational-basis scrutiny and will be upheld if it is rationally related to a legitimate government interest.
Facts:
- In 1985, the city of Dallas, Texas, passed an ordinance creating 'Class E' dance halls.
- The ordinance restricted admission to these dance halls to individuals between the ages of 14 and 18, with exceptions for parents, guardians, law enforcement, and staff.
- The stated purpose of the ordinance was to provide a safe social environment where teenagers could socialize without the potentially detrimental influences of older teenagers and young adults.
- Respondent, the operator of the Twilight Skating Rink, obtained a license for a Class E dance hall within his facility.
- The dance hall area was separated from the all-ages roller-skating rink by movable cones, and both areas played the same music.
- The dance hall served as many as 1,000 patrons per night, most of whom were strangers to one another.
- The establishment did not serve alcohol and had security personnel present.
Procedural Posture:
- The respondent, a dance hall owner, sued the city of Dallas in a Texas state trial court, seeking to enjoin the enforcement of the age-restricted dance hall ordinance.
- The trial court upheld the ordinance, finding it was rationally related to the city's legitimate interests.
- The owner appealed to the Texas Court of Appeals.
- The Texas Court of Appeals reversed in part, striking down the age restriction as a violation of minors' First Amendment associational rights under strict scrutiny.
- The city of Dallas (petitioner) successfully petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does a city ordinance that restricts admission to certain dance halls to persons between the ages of 14 and 18 violate the First Amendment right of association?
Opinions:
Majority - Chief Justice Rehnquist
No. The Dallas ordinance does not violate the First Amendment because recreational dancing in a public dance hall is not a constitutionally protected form of association. The Court recognized two forms of protected association: intimate association (concerning personal relationships) and expressive association (for the purpose of engaging in First Amendment activities like speech or political advocacy). The gathering of hundreds of strangers at a dance hall fits neither category. Because no fundamental right is implicated, the ordinance is subject only to rational-basis review. The city's goal of protecting minors from the corrupting influences of older adults (related to drugs, alcohol, and sex) is a legitimate government interest, and the age restriction is rationally related to achieving that goal. The ordinance does not need to be perfectly crafted or the least restrictive means to survive this lenient standard of review.
Concurring - Justice Stevens
No. While the opportunity to make friends and socialize is an aspect of liberty protected by the Fourteenth Amendment's substantive due process clause, the city has adequately justified the ordinance's modest impairment of that liberty. The ordinance is a reasonable measure to protect teenagers and may, in fact, provide them with a greater opportunity to associate safely. Therefore, the judgment of the court is correct, although the analysis should have been based on substantive due process rather than the First Amendment's right of association.
Analysis:
This decision significantly clarifies and narrows the scope of the First Amendment's freedom of association, confirming that it does not extend to generalized social activities. By firmly applying the two-part framework from Roberts v. United States Jaycees (intimate and expressive association), the Court prevented the expansion of fundamental rights to include recreational conduct. This solidifies the use of the highly deferential rational-basis test for economic and social regulations that do not target a suspect class or impinge upon a recognized fundamental right, granting local governments broad authority to legislate for the health, safety, and welfare of minors.
