HomeMy WebLinkAbout1993-01-26 - AGENDA REPORTS - ADULT BUSINESS REGS (2)AGENDA REPORT
City Manager ApproAby:, �.
Item to be presenteLL,,.,,,CONSENT CALENDAR Lynn M. Harris *- 7V , raj
DATE: January 26, 1993
SUBJECT: ' Adult Business Regulations
DEPARTMENT: Community Development
BACKGROUND
At Its November 10, 1992, meeting, under Council discussion Items, the Council requested the staff
to return to the Council with Information on adult business regulation, Including whether or not the
Municipal Code has this regulation. This research is without the City Attorney's Involvement.
Land use laws addressing adult businesses are legal only if they regulate a legitimate and
substantial government/community interest. A rational relationship and connection must be
demonstrated between adult businesses and the potential negative secondary effects on the public
welfare resulting from their operation. Constitutionally, adult businesses cannot be regulated solely
for content. This key point Is further explained In the Summary of Adult Business Regulations
(attached). Also, Information is provided on two adult business ordinances adopted by Lancaster
and Ontario. Santa Clarita's ordinance is stronger than the Lancaster ordinance because of the
conditional use permit requirement, which Is not part of the Lancaster ordinance.
As part of the Unified Development Code (UDC), adopted November 24, 1992, Section 17.13.050
(General Commercial Uses, please see attached permitted use chart) limits the location of adult
businesses to three zones: Community Commercial (CC), Industrial Commercial (IC), and Industrial
(1). They are prohibited In all 13 other zones. Section 17.07 (Definitions) provides 10 definitions
(also attached) that define the general array of adult businesses and related terms. Furthermore,
a conditional use permit Is required in all three zones. The other provisions used to review new
development and tenant improvements such as site plan review,.sign review, parking, etc. are also
used. Staff feels that the existing Municipal Code regulations and normal development review
procedures are sufficient to address uses potentially Injurious to the public health, safety and
welfare, and that the UDC should be given the opportunity to prove Itself. The City's ordinance is
much simpler than either the Lancaster or Ontario ordinances. If desired, an ordinance similar to
these could be adopted. Should the Council wish to consider additional material not Included in
the UDC, also attached is a recent magazine article on the subject. It outlines current requirements
and legal Issues. The two options that are available are either to use the City's existing code and
procedures, or adopt a new ordinance.
Take no further action at this time, and rely on existing Municipal Code provisions which address
adult businesses.
ATTACHMENTS
1. Summary of Adult Business Regulations
2. Article, "Regulating Adult Businesses;' Dec. 1992, Western City, League of California Cities
3. Excerpts from the Unified
/Development Code
courciNkladllbwimr /r� — --_. '
�` Agenda Item:
SUMMARY OF ADULT BUSINESS REGULATIONS IN GENERAL
AND OTHER CITIES' ORDINANCES
Balance between freedom of speech and communitv Interests
In crafting adult business regulations, a delicate balance must be maintained between protecting
the major Constitutional right of freedom of speech, and ensuring the well-being of community
Interests. The attached magazine article discusses this Issue In-depth. By law, reasonable
allowance must be maintained to permit appropriate .freedom of speech. This means that a
reasonable opportunity must be given to open and operate adult businesses. In the need for adult
business regulations, the community interest portion of the equation must be oriented toward the
potential "secondary effects" of adult businesses, such as reduced property.values, decline in local
business revenues, Increased vacancies in commercial lease space, and so on. A major point that
courts ruling on such Issues have looked for Is that an adult business ordinance is "content
neutral." This means that the ordinance is one that regulates for reasons other than the form of
speech, or type of merchandise sold. To withstand a legal challenge, the jurisdiction may not
eliminate, discourage, or otherwise suppress a business opportunity based on the content of the
merchandise sold. If these points are not carefully addressed, a risk of denial of Constitutional
rights is a probability.
Basic approaches to adult business regulations
Historically, cities have developed adult business regulations which generally reflect one of three
approaches; dispersion, concentration, or the two combined. The most common is a dispersal
approach. The Intent here Is to disperse adult businesses to the point where no two (or more) are
located in close proximity to each other, and to ensure that they are located a sufficient distance
from what are termed "sensitive uses." Examples of Identified sensitive uses Include residential
neighborhoods, parks and playgrounds, schools, churches, day care centers, and similar areas.
Other development and performance criteria are stated, particularly sign requirements, aesthetics
and hours of operation. The jurisdiction must be able to demonstrate that the secondary effects
of adult businesses are detrimental to community Interests. However, a city may rely on studies
of other cities to show the perceived undesirable effects. In essence, a city Is not required to wait
until it has one or more adult businesses to demonstrate what the secondary effects are.
The second, and a less common approach, is to concentrate adult business uses by allowing them
In one or more particular areas of the jurisdiction by regulation. Then, additional requirements such
as the development and performance criteria described above, can be Imposed, usually, less
restrictive.
A third approach Is a combination of the two. It establishes a minimum number of zones in which
adult businesses can be located, and provides location requirements within those zones.
Effectively, the adult businesses are both concentrated and dispersed.
Santa Ciarita
Existing provisions of the Unified Development Code combine these two methods. By potentially
allowing adult businesses in only three zones, the number of areas in the City where they can be
located Is limited. These zones are generally located in areas away from most of the sensitive uses
In the City. Additionally, a conditional use permit Is required. This provides further review
capability to ensure compatibility.
Lancaster:
Since the Council mentioned the Lancaster ordinance at the November 10th City Council meeting,
a summary of that ordinance is provided here. The ordinance begins with a list of definitions of
types of adult businesses and related terms, then establishes location requirements, criteria for
violations and penalties, business permit and application requirements, transfer of permit, and
performance standards (Including video regulations, prohibition of minors, advertising, and hours
of operation). The Lancaster ordinance Is a combined dispersal and concentration ordinance as
described above. It limits adult businesses to Just one zone, the Heavy Industrial zone, and
provides location criteria.
Ontario:
The attached article from Western City magazine describes the experience of the City of Ontario
In formulating an adult business ordinance.. Ontario utilized an extensive nine-month public
participation process to develop Its ordinance. The Ontario ordinance consists of similar, but
fewer, requirements to the Lancaster ordinance. It Is comprised of a list of definitions of adult
businesses and related terms, permitted zones (as in the Lancaster ordinance, one zone only,
Heavy Manufacturing), conditional use permit requirements, location standards, development
standards, and provisions for the amortization of existing adult businesses.
by Jerry Haag and Steven T. Mattas
Regulating adult businesses In California today involves solving
a complex equation — balancing legal Issues, land use plan-
ning considerations, community Interests and the rights of
adult business owners and operators. This article describes Ontario,
California's recent experiences with the adult business ordinance
update process In a climate of changing legal requirements and
strong citizen interest. The authors believe Ontario's experience
can be used as a blueprint for other communities desiring to under-
take similar efforts.
Ontario's interest in adopting revised
adult business requirements was sparked
by the 1990 opening of an adult video store
in a new industrial park. The use violated
the city's mid-1970s adult business require-
ments, but city leaders realized that ordi.
nance needed updating if it were to be
enforceable. The nine-month planning pro-
cess undertaken by Ontario, culminating in
the preparation and adoption of a new ordi-
nance was led by Michael E. O'Connor,
Interim City Manager of Ontario. The prim
mary issues included:
WESTERN Crry, DECEMBER 1992
Continued
Regulating Adult Businesses, Continued
-Developing an understanding of signifi-
cant legal issues.
•Defining adult businesses to be regulated.
*Determining negative secondary effects
of adult uses.
•Identifying sensitive land uses.
•Identifying potential locations for new
adult businesses.
-Establishing development and perfor-
mance standards.
•Determining an adequate permit review
process.
• Dealing with existing adult
*Accommodating diverse
community and business
interests.
Each of these topics is
discussed below.
Legal Issues
everal court- deci-
sions directly affect
local agencies ability
to regulate adult business-
es. These decisions permit
municipal regulation of the
external appearance and
operation of adult facilities
for the purpose of control-
ling the negative secondary .
effects associated with
adult businesses and pre-
serving the quality of urban
life. However, such regula-
tions cannot limit or restrict
the type of material sold or
- displayed within adult busi-
nesses. Local requirements
which purposely attempt to regulate the sale
and content of adult materials violate the
First Amendment to the United States
Constitution.
The leading United States Supreme
Court case regarding adult businesses is
City of Renton v. Playtime Theatres, Inc.
(1986) 106 S. Ct. 925. In Renton, the
Supreme Court held an adult business ordi-
nance will be analyzed as a "content neutral
time, place, and manner speech regulation"
where the city's "predominant concerns" in
adopting the ordinance is the secondary
effects ofadult businesses on the community
and not the content of the speech involved.
A content neutral ordinance is one that
regulates for reasons other than the form of
speech expressed. For example, in Renton,
the Supreme Court recognized the City of
Renton was regulating the secondary effects
including crime and decreased property val-
ues of the adult businesses as opposed to
the content of the materials sold by adult
businesses. When analyzing whether an on
dinance is content neutral, the courts look to
the language of intent expressed in the ordi•
nance.Therefore, cities must ensure the lan-
guage of intent expressly identifies that the
city's purpose is to regulate the secondary
effects of adult businesses and not the con -
of adult business definitions may be found in
the recently -published reference text Time,
Place and Manner ofBusinessActivity Bull
and Sears, Southwest Legal Press, 1990).
Identifying Negative
Secondary Effects
s part of the ordinance prepara-
tion process, local agencies must
identify a link, or nexus, between
the presence of adult businesses in the
community and negative secondary ef-
fects. Typically, negative sec-
ondary effects include
such things as lowered
property values, increased
crime and higher commer-
cial vacancy rates. Agen-
cies are not required to
conduct such research
studies themselves. Refer-
ences to previous studies
completed by other juris-
dictions have been deem-
ed sufficient by courts.
(Renton, supra, 106 S.Cttat
931.) A partial list of public
agencies that have already
completed studies includes
Austin, Texas; Phoenix,
Arizona; and Indianapolis,
Indiana. Ontario's new
ordinance relied on a com-
bination of previously -com-
pleted studies supplement-
ed
upplemented with studies of local
conditions.
Jerry Haag is an independent planning consul-
tant
onsultant in Berkeley, California. Steven T. Mattas
is an associate with the law firm of Meyers,
4 Nave, Ribaek & Silver in San Leandro.
Assuming an adult business ordinance is
content neutral, the ordinance will likely be
upheld if it is designed to serve a substan-
tial governmental interest In Renton, the
Supreme Court reaffirmed its prior state-
ments that a city has a substantial govern-
mental interest in attempting to preserve
the quality of urban life by avoiding the sec-
ondary
eaondary effects caused by adult businesses.
Defining An
Adult Business
An integral part of the ordinance
preparation process is defining
what types of activities should be
regulated as adult business activities. As
cities increase their regulation of specific
adult business activities, the business own-
ers become more creative in labeling their
activities. Thus, cities should structure their
definition of an adult business to identify
types of activities and then provide specific
examples of such activities. A helpful source
LEAGUE OF CAMFORW, CMES
Identifying
Sensitive Land Uses
ensitive land uses are those uses
which are likely to be the most
impacted by the proximity of adult
businesses. Typically, such uses include
parks and playgrounds, churches, schools
and day care centers and other places fre-
quented by minors. The list of sensitive
uses can be tailored to meet the unique
needs of individual communities. However,
when cities identify sensitive land uses they
should be aware of the potential impact in
terms of available alternative sites in identi-
fying too many types of sensitive land uses.
Potential. Locations —
Providing Reasonable
Alternative Sites
dult business ordinances must
provide for reasonable alterna-
tive avenues of communication.
According to the U.S. Supreme Court, the
Fust Amendment requires only that (cities)
refrain from effectively denying (adultbusi-
nesses) a reasonable opportunity to open
and operate an adult theatre within the
city." (Renton, supra, at 106 S.C. at 932.)
Thus, a city must allow for a legally ade.
quate number of sites for future adult uses.
In Renton, the Supreme Court instruct-
ed that cities may regulate adult uses by
dispersing them or by effectively concen-
trating them. (Renton, supra, 106 S. Ct. at
93L) Some courts have upheld a com-
bined approach regulating adult uses
both by dispersing them and effectively
concentrating them. For example, in S&G
News u City of Southgate, (ED. MI. 1986)
638 F.Supp.1060,1063, the court upheld a
zoning scheme which limited adult busi-
nesses to C-3 zones and imposed location-
al restrictions (such as 1,000 feet from
other adult uses, 500 feet from residential
dwellings). Other courts have, however,
invalidated ordinances which impose sep-
aration requirements between adult busi-
ness uses and other sensitive uses when
those ordinances result in little opportuni-
ty for an adult business to operate. (See,
Walnut Properties, Inc. v. City of Whittier
(9th Cir. 1988) 861 F.2d 1102 and City of
Stanton v. Cox (1989) 207 Cal.App.3d
1557, 255 Cal.Rptr. 682)
In Walnut Properties, Inc., a federal appel-
late court reviewed Whittler's ordinance
which permitted adult businesses in com-
mercial and industrial zones, but prohibited
them from locating within 500 feet of resi-
dential lots and businesses holding liquor
licenses, and from within 1,000 feet of
schools, churches, parks, or other adult
businesses. In its decision, the court said
the separation requirement rendered the
number of acres where adult businesses
were permitted a meaningless figure.
Instead, the court focused on the number
of potential sites available, which depended
not so much on the total acreage available
under the zoning scheme, but on how that
acreage was dispersed or concentrated
throughout the city. Finding the ordi-
nance would allow only "a small handful"
of adult businesses to operate in the City of
Whittier, the court held the ordinance
unconstitutional. (Walnut Properties, supra,
at 1108-1110.)
Similarly, in City. of Stanton v. Cox, a Cal-
ifornia appellate court invalidated an ordi-
nance which prohibited adult businesses
within 500 feet of any church, school,
park, playground or residential area and
within 1,000 feet of another adult business
as impermissibly restricting access to law-
ful speech, where the town contained only
six sites where, regardless of availability,
an adult business could operate.
In light of the analysis of these post -
Renton cases, a city must ensure location-
Continued
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WESTERN CITY, DECEMBER 1992
Regulating Adult Businesses, Continued
al restrictions prescribed by an adult busi-
ness ordinance allow an opportunity for
an adult business to operate within the
city. While the decision to concentrate or
disperse adult business or apply a com-
bined approach is ultimately a policy deci-
sion, the city should ensure the chosen
approach does not effectively preclude
adult business from locating in the city.
Historically, communities have select-
ed one of three regulatory approaches —
concentrated, dispersed or combined.
The concentrated approach involves cre-
ating a special zone district which places
all adult businesses in one area in a city.-=.
A dispersed approach, allows communi-
ties to distribute adult uses throughout
the community through separation re-
quirements. A combined approach re-
quires adult uses to locate only within
certain zoning districts and requires min-
imum distances between adult business
uses, as well as minimum distances
between adult businesses and other sen-
sitive uses.
Once a location strategy is decided, the
number of potential locations can be esti-
mated through a mapping exercise. First,
zoning districts to accommodate adult
uses are identified (using the concentrat-
ed, dispersed or combination approach),
then all sensitive land uses within appro-
priate zone (s) are mapped and develop-
ment and performance standards applied
(see discussion of such standards,
below). Areas not otherwise excluded as
being too close to sensitive land uses
would therefore be eligible for the loca-
tion of an adult business.
Establishing
Development And
Performance Criteria
Many cities require new adult
businesses to comply with
minimum development and
performance standards, in the context of
minimizing negative secondary effects of
adult uses. Typical standards require a
minimum distance between an adult busi-
ness and sensitive land uses, limitations
on entry by minors, and limitations on
exterior display signs.
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Planning
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Analysis .
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Management
■ Occupancy/Operations
Analysis & Planning
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LEncuE OF CALIFORNIA CMES
Permit Review Process
mes may require new adult uses to
obtain special zoning approvals,
such as conditional use permits.
Care must be taken, however, to ensure that
such requirements are not invalidated as a
prior restraint In a recent case, a California
appellate court invalidated a Los Angeles
County conditional use permit requirement
because of the absence of a specific time
frame within which the county must approve
or deny conditional use permit applications.
(People u Library One (1991) 229 CaLApp.sd
973, 280 CaLRptr. 400) Asimilar ruling also
was made against adult business regulations
adopted by the City of Dallas. (FW/PBS, Inc.
u Dallas (1990) 110 S.Ct 596.) The City of
Ontario responded to this issue by adopting
a sit -month processing period for condition-
al use permits for adult businesses.
Existing Uses
entiment may exist to amortize, or
phase out, adult businesses which
already operate in the community. If
a new ordinance is approved, such busi-
nesses may become legal nonconforming
uses, or may already have existed as legal
non -conforming uses. Amortization of
existing adult business uses may occur,
however, care must be taken to permit
owners of adult uses and opportunity
to recoup their financial investments in
their businesses.
California and federal courts have con-
sistently held that zoning ordinances may
validly provide for the eventual termination
of nonconforming uses without compensa-
tion if the ordinance provides for a reason-
able amortization period commensurate
with the investment involved. Whether a
particular amortization provision provides a
reasonable time period commensurate with
the investment involved depends greatly on
the facts of each individual case. In making
such a determination, the decision-making
body must view several factors and then
balance "the public gain to be derived from
the speedy removal of the nonconforming
use against the private loss which removal
of the use would entail." (Metro Media, Inc.
v. City of San Diego (1980) 26 CaUd 848,
164 Cal.Rptr. 510, 530) Because regulation
of adult businesses raises potential Fust
Amendment concerns, courts more closely
scrutinize amortization provisions that,
when combined with restrictive adult busi-
ness ordinances, operate to severely
restrict opportunities for protected expres-
sion. (Purple Onion, Inc. u Jackson (N.D.
GA. 1981) 511 F.Supp.1207) .
Courts have identified a number of fac-
tors cities should consider in making deter-
minations regarding the reasonableness of
a particular amortization period. Some of
these factors include:
i. The adult business owner's financial
investment in the adult business;
2. The present actual and depreciated value
of the business improvements;
3. The remaining lease term;
4. The cost of relocating the adultbusiness;
5. The ability of the business and/or land
owner to change the use to a conform-
ing use;
6. The date upon which the property owner
and/or business owner received notice
of the nonconforming status of his or
her use; and
7. The effects on the health, safety and wel-
fare of surrounding businesses and uses
if the adult business is permitted to oper.
ate beyond the initial amortization peri-
od. Metro Media, Inc. v. City of San
Diego, supra; and 11126 Baltimore
Boulevard v Prince George's County (4th
Cir. 1989) 886 F.2d 1415)
Under Ontario's new ordinance, existing
adult businesses have a maximum of two
years to comply with the provisions of the
ordinance which would include relocating
to areas within the city where adult busi-
nesses are conditionally permitted uses.
The ordinance does, however, provide an
administrative process whereby an existing
adult business can request the extension of
its amortization period. Such an administra.
tive process is desirable because it permits
the city to evaluate carefully ther reason -
al leness of the amortization period for
each adult business and because the pro-
cess creates an administrative record.
Community Review
pdating adult regulations can
become a potentially explosive
issue in the community. Residents
may have strong feelings regarding the
location of future adult businesses, espe-
cially if adult uses are anywhere near their
neighborhood. Adult business owners want
a fair consideration as to their constitutional
rights to operate. To understand the full
range of feelings in Ontario, the City
Council directed that a series of community
meetings be held to fully explain legal
issues to the public and a solicit input as to
range of acceptable regulatory solutions.
Conclusion
0 ntario's experience regulating
adult businesses can be used by
other communities faced with
the same issues, so long as individual dif-
ferences between communities are rec-
ognized. The entire process took approx-
imately nine months. The stakes are
high and the pitfalls are many. But suc-
cessfully dealing with the legal, planning
and citizen involvement issues can signif-
icantly assist in improving the appear-
ance and quality of life in our communi-
ties while upholding our constitutional
right of free speech.
■
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California Energy Commission
upleased to announce the award winners of
"Ener�yF�re x i vnent"
-Berkeley • Best Large City
for its North and West Senior Centers,
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Seal Beach -.Best Medium -Sized City
for its City Hall and Marina Community Center
Lonna Linda Best Small City
for its Public Library and Fire Department Building
The Commission's Energy Partnership Program assists cities and
counties in becoming more energy efficient. Each year, it gives
special recognition to three cities for their superior
energy -efficiency accomplishments.
WESTERN CrtY, DECEMBER 1992
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2-7
DEVELOPMENT CODE
City of Santa Clarita, California
11124192
UDC ADULT BUSINESSES -RELATED DEFINITIONS
5. ADULT shall mean a person who is 18 years of age or older.
6. ADULT BOOKSTORE shall mean an establishment that devotes more than 15% of the total floor area
utilized for the display of books and periodicals to the display and sale of the following; books, magazines,
periodicals, or other printed matter, or photographs, films, motion pictures, video cassettes, slides, tapes,
records, or other forms of visual or audio representations which are characterized by an emphasis upon the
depiction or description of specified sexual activities or specified anatomical instruments, devices or
paraphernalia which are designed for use in connection with specified sexual activities.
An adult bookstore does not include an establishment that sells books or periodicals as an incidental or
accessory part of its principal stock -in -trade and does not devote more than 15% of the total floor area of
the establishment to the sale of adult only books and periodicals.
7. ADULT BUSINESS shall meat any business which, because minors are excluded by virtue of their age as
it prevailing business practice, is not customarily open to the general public, including but not limited to,
an adult arcade, adult bookstore, adult theater, cabaret, love parlor, massage parlor, model studio, nude
studio, sexual catharsis center, sexual encounter shop, sexual novelty store or any other similar use wherein
the preponderant business is the offering of services, materials and/or products which have as their dominant
theme the sexual arousal, sexual gratification and/or sexual stimulation of a customer.
This definition does not apply, nor shall be interpreted to apply, to any business conducted, operated by or
employing licensed chiropractors, licensed physicians, licensed physical therapists, licensed psychologists,
licensed social workers or licensed marriage and family counselors when performing functions under or
pursuant to the respective license held.
8. ADULT CABARET shall mean a nightclub, bar; theater, restaurant or similar establishment which regularly
features live performances which are distinguished or characterized by an emphasis on specified sexual
activities or by exposure of specified anatomical areas and/or which regularly features films, motion
pictures, video cassettes, slides or other photographic reproductions which are distinguished or characterized
by an emphasis upon the depiction or description of specified sexual activities or specified anatomical areas
for observation by patrons.
10. ADULT HOTEL OR MOTEL shall mean a hotel, motel or similar establishment offering public
accommodations for any form of consideration which provides patrons with closed-circuit televisions
transmissions, films, motion pictures, video cassettes, slides or other photographic reproductions which are
distinguished or characterized by an emphasis upon the depiction or description of specified sexual activities
or specified anatomical areas.
11, ADULT MOTION PICTURE ARCADE shall mean anyplace to which the adult public is permitted or
invited where coin or slug operated or electronically, electrically, or mechanically controlled still or motion
picture machines, projectors, or other image -producing devices are maintained to show images to five or
fewer persons per machine at any one time, and where the images so displayed are distinguished or
characterized by an emmphasis on depicting or describing specified sexual activities or specified anatomical
areas for observation of patrons.
12. ADULT MOTION PICTURE THEATER shall mean an establishment, with the capacity of 50 or more
persons, where, for any form of consideration, films, motion pictures, video cassettes, slides or similar
photographic reproductions are shown, and in which a substantial portion of the total presentation time is
devoted to the showing of material which is characterized by an emphasis upon the depiction or description
of specified sexual activities or specified anatomical areas for observation by patrons.
194. SEXUAL ENCOUNTER ESTABLISHMENT shall mean an establishment, other than a hotel, motel, or
similar establishment offering public accommodations, which, for any form of consideration, provides a
place where two or more persons may congregate, associate, or consort in connection with specked sexual
activities or the exposure of specified anatomical arca. This definition does not include and establishment
where a medical practitioner, psychologist, psychiatrist or similar professional person licensed by the State
of California engages in sexual therapy. For the purposes of these regulations, sexual encounter
embfishment shall include massage or rap parlor and other similar establishments.
239. SPECIFIC ANATOMICAL AREAS
a. Less than completely and opaquely covered human genitals, pubic region, buttocks, anus, or female
breasts below a point immediately above the top of the areolae; or
b. Human male genitals in a discernibly turgid state, even if completely and opaquely covered.
240. SPECIFIED SEXUAL ACTIVITIES
a. The fondling or other touching of human genitals, pubic region, buttocks, anus, or female breasts;
or
b. Sex acts, normal or perverted, actual or simulated, including intercourse, oral copulation, or
sodomy; or
C. Masturbation, actual or simulated; or
d. Excretory functions as part of or in connection with any of the activities set forth in a through c
above.
advmceWdcadult.kmk