Randal R. Morrison’s

Petitions pending:

Artistic Murals or Oversize Advertising Signs? Beverly Blvd. v. West Hollywood concerns multi-story images ("tall wall signs") installed on the sides of an office building on the famed Sunset Blvd. In an unpublished decision, the Ninth Circuit held that one image (an Andy Warhol painting) was a decorative display and not within the definition of "advertising" as used in state law (B&P 5412). However, the other image (a Veteran’s mural) was advertising because it contained lettering. Because the Vet’s ad was not "lawfully erected," there was no protectable property interest in the images, and thus there could be no "taking" of property. (9^th Cir Nos 05-55961, 05-55970, 05-56384, June 5, 2007, not officially published, not citeable, not precedential, available at: 238 Fed.Appx. 210, 2007 WL 1649843).

Beverly’s petition: The city’s rules about tall wall signs serves only the esthetic interest, which is insufficient justification. The Ninth Circuit used the wrong definition of "property." The case should be used to re-examine the Central Hudson test for restrictions on commercial speech, and to dispel the confusion created by the five-opinion decision in Metromedia v. San Diego (1981).

West Hollywood’s opposition: The "tall wall" rules serve both the esthetic and safety interests; the regulation "merely limits the zone in which enormous, multi-story signs may be erected. And it does not distinguish between commercial and noncommercial speech." Since the Ninth Circuit decision is not officially published, it is not precedential and therefore is not a good vehicle for revisiting Central Hudson or Metromedia.

[Another West Hollywood / tall wall case: Regency Outdoor v. West Hollywood, 153 CalApp4th 825 (2007) (corporation did not have standing to challenge "tall wall sign" rules under the California Environmental Quality Act); another oversize mural case: People v. Stross, 2008 WL 466996 (MI App No 271764, Feb 21, 2008]

Permit Processing Time. In Covenant Media SC v. North Charleston, 493 F3d 421(2007)

the Fourth Circuit held that billboard permits were properly denied because the proposed billboard violated a separation between signs rule. Further, since the sign regulation was content neutral, explicit time limitations on decision making were not constitutionally required. The sign company’s petition sought review on the decision time issue. Petition denied, US Supreme No 07-587, Jan. 7, 2008, 128 SCt 914, 76 USLW 3345, 3336, 255 [Disclosure: Randal R. Morrison defended the City of North Charleston.]

Car for Sale. Resident challenged city’s ban on parking private cars with "for sale" sign on public street. Held: a fifteen judge ("en banc") panel of the Sixth Circuit ruled 8 -7 that the city had not provided evidence to show the rule actually advanced the city’s interests, and could not be viewed as content neutral, time place and manner rule. Pagan v. Fruchey, 492 F3d 766 (6^th Cir No 04-4414, June 29, 2007). Petition denied by US Supreme Dec 3, 2007 (No 07-420, 128 SCt 711, 169 LEd2d 554, 76 USLW 3286, 3287).

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Can (or should) a city ban or limit signs with changeable images or digital display faces? This question currently is being debated at all levels of government, nationwide, especially in the context of whether there is, or should be, a right under state law to convert an existing legal sign to digital display, or whether that decision should be left to local governments.

Electronic Message Centers. Jewelry store challenged city law banning all Electronic Messaging Centers ("EMCs") – those that display electronically changeable messages and allow illuminated text that can change frequently, by scrolling or flashing. Held: The complete ban on EMCs meets all the tests for a time, place and manner rule: it is content neutral, narrowly tailored to serve significant gov’t interests and leaves open ample alternatives. The ban on EMCs is constitutional. Naser Jewelers v. Concord NH, 513 F3d 27 (1^st Cir No 07-2098, Jan 18, 2008).

Similar case, same city: Car dealer, also in Concord NH, was denied permit to erect an electronic changeable copy sign on its property to replace an existing manually changeable sign. Held: The City need not provide detailed proof that the regulation advances its purported interests of safety and aesthetics, . . . the trial court erred in substituting its judgment for that of the City’s that prohibiting animated, flashing signs containing commercial advertising will ‘enhance the appearance and aesthetic environment of the City’ and ‘improve traffic safety.’ City’s ban on moving image signs is valid. Carlson’s Chrysler v. City of Concord, 938 A2d 69 (NH SC No 2006-362, Nov 8, 2007).

Oscillating searchlights. Car dealer used portable searchlights to draw attention to location for special sales and events. When the search lights oscillated, they fell within the definition of "sign" and were banned as "rotating, or oscillating signs." PA Commonwealth Court: There was no error in finding that these oscillating searchlights constituted prohibited signs. Sutliff v. Silver Spring Tp Zoning Hearing Bd., 933 A2d 1079 (PA Commonwealth Ct No 490 CD 2007, Oct 2, 2007).

LED conversion: Billboard operator sought permit to convert existing, legal billboard to LED display, without changing the superstructure of the signs. City said signco’s application was incomplete and requested more information. 123 days later signco claimed the permit was "deemed approved" because the city had not taken formal action in the time required by state law. Held: The state law applies to residences and other structures that relate to them. A billboard is not an accessory structure to a dwelling unit. Conversion to LED display is not a right of modernization. City could demand CUP and site plan approval. Lamar Adv v. Zoning Hearing Bd of Monroeville, 939 A2d 994 (PA Commonwealth Ct., No 1117 CD 2007, Dec 17, 2007, reargument denied Feb 13, 2008).

LED conversion (case 2): Georgia state law states that signs using "nonmechanical electronic multiple message signs" are permissible under certain circumstances. City denied signco’s application to convert existing sign to LED display, as violating city law prohibiting "flashing, or blinking signs or signs using varying light intensity . . ." Held: City law grants the planning dept total control over whether to require a permit, and leaves no guidance for this discretion; this creates the possibility of content-based discrimination. The city’s sign code is an unconstitutional prior restraint on free speech. Signco is entitled to nominal damages, and the chance to prove it suffered actual damages for deprivation of its rights. Lamar v. Marietta GA, __ FS2d __, 2008 WL 696683 (USDC ND GA, No 1:07-cv-00764, Feb 25, 2008).

Conversion to electronic display: Owner of legal, non-conforming billboard converted display face to electronic message board; city ordered it removed based on a law forbidding structural alteration or enlargement of legal non-conformity. Signco’s structural engineer said that addition of the electronic message board did "not increase the force in any structural element by more than [five percent]" and was not, therefore, " ‘structural’ as defined by the International Building Code. Held: the electronic message board added between 3,000 and 3,500 pounds to the weight of the billboard. While it did not increase the height, length, or the square footage of its advertising surface area, it did increase the depth. The addition of the message board "enlarged" the billboard in both dimension and weight, and was thus illegal. The illegality could not be cured by returning to the original display face. Adams Outdoor v. Bd Zoning Appeals, Virginia Beach, 645 SE2d 271 (VA SC No 061272, June 8, 2007).

Furniture store’s challenge to rule prohibiting electronic signs was mooted by city’s enactment of modified ordinance, Chapin Furniture Outlet v. Chapin, 252 FedAppx 566 , 2007 WL 3193854 (4^th Cir No 06-2129, Oct 30, 2007; not officially reported).

Electronic sign for church: City denied church’s application for variance to rebuild existing sign, increasing size (by ten times the normal rule) and height (four times), and adding electronically changeable copy. Church challenged the denial on the basis of the federal Religious Land Use and Institutionalized Persons Act (RLUIPA). Held: The Church has not been denied any use of a sign as a means of evangelism, but only the non-conforming use of a sign that cannot be as large and eye-catching as the church might desire. Denial of its variance burdens the Church’s religious exercise, but not enough to to make any use of a sign for uplift and recruitment "effectively impracticable" or to compel the congregants to "violate [their religious] beliefs." The standard for an RLUIPA violation is not met; there was no error in denying the variance. Trinity Assembly of God v. People’s Counsel for Baltimore County, 178 MdApp 232, 941 A2d 560 (MD App No 2840, Feb 6, 2008).

Rotating display panels. Signco operates large vans with billboards on both sides and rear; triangular panels rotate every 8 seconds. County cited signco for violating rule against signs with movement or motion. Held: The charging sections ban moveable image signs but make exception for time and temperature and barber poles; thus the sign ordinance is content based. Because signco is likely to prevail in the case, the county is preliminarily enjoined from enforcing these provisions. Bonita Media v. Collier County (FL) Code Enforcement, 2008 WL 423449 (USDC MD FL No 2:07-cv-411, (Feb 13, 2008).) [Compare with next case, Desert Outdoor v. Oakland.]

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Exception for time and temp. Signco erected two freeway visible billboards without permits, and sought a permit for a third. City demanded that the two signs be removed, and denied a permit for the third. Signco sued, claiming unconstitutionality of the sign regs. Held: The city interpreted its ban on "advertising" on freeway visible signs as inapplicable to non-commercial speech; the court accepts this interpretation. Although time and temperature indicators are non-commercial, the exception for them can be interpreted to mean that the city allows T&T as part of on-site commercial signs. The city’s sign regulations are constitutional. Desert Outdoor v. Oakland, 506 F3d 798 (9^th Cir No 05-15501, Oct 30, 2007).

Favoring non-commercial speech. Without obtaining city permits, signco constructed signs in the "ETJ" (extra-territorial jurisdiction) of Houston TX, a home rule city (and the nation’s largest city without zoning). In earlier litigation, a TX state appellate court ruled that under state law the city’s sign reg jurisdiction extended to the entire ETJ, and was not limited to signs adjacent to rural roads. (Brooks v. State, 226 SW3d 607, 610, TexApp-Houston No. 01-06-00312, Feb 15, 2007). City then commenced new enforcement action in state court against signco and its advertiser customers. Signco then filed a new action in federal court, asserting unconstitutionality of the city’s sign regulations by exempting from regulation all signs that were used exclusively for non-commercial messages (politics, religion, protest, etc). Held: the prior state court decision did not prevent the federal court from considering the constitutional claims; "City shall be enjoined from enforcing its Sign Code, . . . because there is a substantial likelihood that its content-based distinction between commercial and noncommercial speech violates the Free Speech Clause . . . RTM Media v. Houston, 518 FS2d 866 (USDC SD TX No. 07-2944, Sep 26, 2007). On the City’s motion for reconsideration, the Court clarified the Sept 26 order as preventing enforcement of the city law "against RTM Media, L.L.C., its advertisers, vendors, owners, lessors and/or lessees, and (2) from fining or threatening to fine advertisers placing advertisements on billboards owned by RTM Media, L.L.C. Except as otherwise provided in this clarification, the enforcement of the Sign Code is not enjoined." RTM, 2007 WL 5006527, Oct 16, 2007. [Note: the City, but not signco RTM, has filed a motion for summary judgment, which is now pending. Disclosure: Randal R. Morrison is a consultant to the City of Houston TX on sign regulation matters, but is not representing the City in this case.]

Pre-emption by state law. Owner of two properties wished to put a sign on one property directing traffic to the other property. Such sign was authorized by state implementing the federal Highway Beautification Act, but banned by town law. Held: The state law allows local law to be more restrictive. The Town’s ban on directional signs in areas zoned agricultural is not preempted, and can be enforced to prohibit the sign. Donaldson v. Spring Valley, 2008 WL 732001 (WI App No 2007AP1418, Mar 20, 2008) (final publication decision pending).

Billboards on residential land. Two billboards were constructed in 1968; in 1993 the owner applied for permits. State DOT denied permits because the signs were located on residentially zoned land. Held: Just because the residential zoning designation contained a commercial permitted use does not qualify the area for a billboard in a commercial area. Permits cannot be granted for these signs. Indiana DOT v. US Outdoor, 2008 WL 638393 (IN App No 49A02-0702-CV-167, Mar 11, 2008, unpublished, non-precedential, not citeable).

Mootness: Signco was denied conditional use permits to build new billboards. It sued to challenge the CUP denials. City then amended code to prohibit all billboards, and moved to dismiss. Held: the amended ordinance moots claims for permits, but the issue of potential damages remains open for further consideration in the trial court. Outdoor Media Group v. City of Beaumont, 506 F3d 895 (9^th Cir No 05-56620, Nov 1, 2007) [Disclosure: Randal R. Morrison is defending the City of Beaumont in this case.]

Failed settlement: After being sued by billboard company, city amended sign ordinance. Signco claims it entered into an oral settlement agreement with city’s counsel. Held: The amended sign ordinance mooted the suit. The settlement contract was not signed by the city’s mayor, as is required by state law (Cal Gov’t Code 40602.). Case dismissed. Get Outdoors v. El Cajon CA, 2007 WL 4170230 (USDC SD CA No 03-cv-1437, Nov 20, 2007). [Disclosure: Randal R. Morrison consulted with El Cajon on the sign ordinance revision, but did not represent the city in litigation.]

San Diego: Billboard company’s permit applications were denied because 1) the sign ordinance banned new off-premises signs, 2) the proposed signs violated size and height rules. Signco sued, asserting 14 different bases for unconstitutionality of the city sign law. Held: signco has standing only to challenge the provisions that apply to its applications. "Because standing is addressed on a claim by claim basis, an unfavorable decision on the merits of one claim may well defeat standing on another claim if it defeats the plaintiff's ability to seek redress." The size and height rules are valid, so it is unnecessary to address the constitutionality of the ban on off-site signs. Signco did not suffer any injury which is compensable by even nominal damages. It lacks standing to challenge the permit procedure as a prior restraint. Get Outdoors v. San Diego, 506 F3d 886 (9^th Cir No 05-56366, Nov 1, 2007). Similar cases decided by unpublished memoranda issued the same day, and relying primarily on the published San Diego case: Get Outdoors v. Chula Vista, 9^th Cir No 05-56374, 2007 WL 3230393, and Get Outdoors v. Lemon Grove, 253 FedAppx 636, 2007 WL 3230395. [Disclosure: Randal R. Morrison defended the cities of San Diego, Chula Vista and Lemon Grove in these cases.]

* Midwest Media v. Symmes Tp OH, 503 F3d 456 (6th Cir No 06-3828, Oct 1, 2007) (violations of size and height limits, and ban on off-site signs; no standing to challenge other provisions) (denial of rehearing and dissent therefrom: 512 F3d 338, 6^th Cir Jan 10, 2008);

* Covenant Media SC v. Surfside Beach SC, 2007 WL 2981942 (USDC SC No 4:05-2029, Sept 26, 2007) (even if applications were submitted as claimed, they would have been denied for violation of setback requirement; signco lacked standing to challenge inapplicable parts of sign code);

* Covenant Media SC v. North Myrtle Beach SC, 2007 WL 2981934 (USDC SC No 4:04-22957, Sept 26, 2007) (violation of size, height, and separation limits);

* Bill Salter Advert. v. Atmore AL, 2007 WL 3025032 (USDC SD AL No 05-0720, Oct 12, 2007) (signco had standing only to challenge rules about rebuilding signs after storm damage);

* Covenant Media NC v. Monroe NC, 2007 WL 655319 (USDC WD NC No 3:04cv586, Mar 1, 2007) (Permits were denied based on valid restrictions of height, set-back and spacing; denials are not "injuries" in the constitutional sense; signco has no standing.)

Signco standing in state courts. The Georgia Supreme Court has now joined the federal courts on the standing issue, holding that the challenger "must still show harm by the provisions being challenged as unconstitutional," and refused to address the sign company’s "enumerations of error attacking the entire statute on constitutional grounds." Granite State Outdoor v. Roswell, __ SE2d __, 2008 WL 622814 (GA SC No S07A1885, Mar 10, 2008).

Standing of governmental agencies: Detroit Board of Zoning Appeals granted variance to allow signco to hang "super graphic" advertisements on two selected properties. City’s Downtown Redevelopment Authority challenged the variance. Held: the Authority has shown that it "has made substantial investments in the area surrounding the variance, that it owns nearby buildings, and that it has a supervisory authority over the development district that encompasses the variance . . . the variance will potentially cause economic injury to its interests. Because a judgment in favor of plaintiff will eliminate these injuries, plaintiff has established standing to challenge the variance." City of Detroit Downtown Development Authority v. US Outdoor Advertising, 480 Mich 991, 742 NW2d 133 (MI SC Dkt No 133992, Dec 21, 2007).

Rebuild. Signco applied to expand existing non-elevated billboard, increasing size and height, and convert to double face. Permit was initially granted, but upon reinspection, permit was revoked by NJ DOT as being too close to a pre-existing sign. Held: the permit was granted subject to compliance with all applicable rules; when the separation rule violation was discovered, DOT properly revoked the permit. Steen Outdoor v. NJ Dept of Transportation, 2008 WL 114194 (NJ Super AppDiv, Jan 14, 2008, not officially reported).

Repair. TN DOT says billboard did not meet the rules for repairing a storm damaged sign; original sign was on wood posts with a metal face; the replacement was a monopole with wood face. Administrative law judge held that the "like materials" rule was violated and ordered the new sign removed, and cancelled the permit for the original sign. Held: trial court did not have complete administrative record when it made its decision. Case sent back to trial court for new decision based on complete record. Clear Channel v. TN DOT, 2008 WL 426019 (TN App No M2006-02322, Feb 13, 2008). [Compare with next case.]

Repair. Nonconforming sign was destroyed by Hurricane Dennis. FL DOT determined that cost of repair exceeded 50% of sign’s value prior to hurricane, thus making it "destroyed" under state law. Held: Sufficient evidence supported the "destroyed" finding; cancellation of the permit was valid. Bill Salter Adv v. Dept. of Trans, __ So2d __, 2008 WL 373617 (FL App No 1D07-2599, Feb 13, 2008.)

Relocation: After billboard was built under County permit, County adopted new sign law which prohibited outdoor advertising signs in that area, making the sign "legal, non-conforming." Later, to accommodate freeway widening, at DOT’s request, signco moved sign 50 feet, without informing County. When the move was discovered, County then demanded removal of the non-conforming sign. Held: State law allows local regulation of signs, but here the relocation of the sign was expressly authorized by state law, and thus pre-empts the County’s law. Relocation was legal. Lamar v. Stanly County Zoning Bd of Adj, 650 SE2d 37 (NC App No COA06-993, Sept 18, 2007).

New sign face: When County discovered that display face on existing signs had been replaced, with a modified method of attachment, it demanded a building permit for each modified sign. Held: although the evidence was conflicting, there was enough evidence to uphold the trial court’s determination that no new building permit was required. Lamar Outdoor v. Lima/Allen Cty Bldg Dept, 2007 WL 2758578 (OH App No 1-07-10, Sept 24, 2007).

Public housing. Tenants of public housing challenged rules prohibiting posting of signs on exterior of doors of rented apartments. Held: The door, including the exterior, is part of the leased premises, and is subject to constitutional principles for residential signs. "Residential signs have great value derived from their clear association with an identified speaker. . . Displaying a sign from one’s own residence often carries a message quite distinct from placing the same sign someplace else . . ." It does not matter that the tenants do not own the unit. The complete ban on door signs is not justified. Resident Action Council v. Seattle Housing Authority, 162 Wash2d 773, 174 P3^d 84 (WA SC No 80006-5, Jan 3, 2008).

Common areas of condos. Owner of condo unit had a right under state law and condo rules to post sale or lease signs in the windows of the owned unit, but had no right to post signs in the common areas. Fourth LaCosta Condominium Owners Ass’n v. Seith, 159 CalApp4th 563 (CalApp 4^th Dist. No D049276, Jan 4, 2008).

HOA rules limiting signs. Homeowners Ass’n purposes were primarily private; Ass’n was not subject to constitutional guarantees of free expression and assembly. Relationship between association and its members is contractual; covenants appear in all deeds. The sign rules are reasonable: homeowners are permitted to place a single sign in each window and signs may be placed in the flower beds adjacent to the homes. The Association’s sign rules are valid. Committee For A Better Twin Rivers v. Twin Rivers Homeowners’ Ass’n, 192 NJ 344, 929 A2d 1060 (NJ SC July 26, 2007).

John 3:16. State DMV denied application for custom license plate; applicant’s 1^st, 2d and 3d choices were: "John316," "JN316," and "JN36TN;" he stated on the app that all referred to the biblical passage "For God so loved the world . . ." Held: Under state law, vanity plates are subject to several rules, including references "in any language, to a . . . religion . . . deity. . ." The DMV has the right to prohibit religious messages on license plates provided it does not discriminate based on the particular message or viewpoint. DMV might have approved Bryne’s application without knowledge of his intent to express his religious viewpoint, when he stated his meaning as religious, the DMV properly applied the rule prohibiting religious statements on state license plates. Byrne v. Lunderville, 2007 WL 2892620 (USDC VT No 1:05-cv-15, Sept 28, 2007) [Comment: this decision contains an excellent summary of many "custom license plate" cases. Contrast its conclusion with the next case.]

"Choose Life" plates. AZ State Licence Plate Commission denied group’s application for "Choose Life" plates. Held: Even though plates are issued by the state, organization plates are primarily private speech; the state has created a limited forum for non-profits. State’s decision to stay out of the Choose Life / Pro Choice debate was viewpoint discriminatory. "It is as objectionable to exclude both a theistic and an atheistic perspective on the debate as it is to exclude one, the other, or yet another political, economic or social viewpoint." Although the rules messages promoting "a specific product for sale, or a specific religion, faith, or antireligious belief," they contain no objective criteria for limiting controversial material. The Commission acted unreasonably by denying Life Coalition’s application for reasons not statutorily based or related to the purpose of the limited public forum. Arizona Life Commission v. Stanton, 515 F3d 956 (9^th Cir No 05-16971, Jan 28, 2008.)

Private property as public forum? In Robins v. Pruneyard, 23 Cal3d 899 (1979), the California Supreme Court held that the state constitution provided a right to gather petition signatures at a large, regional shopping center, against the wishes of the private owner. US Supreme held that the California rule did not violate the US constitution, Pruneyard v. Robins, 447 US 74 (1980). Cal Supreme recently reconfirmed the Pruneyard rule in Fashion Valley Mall v. NLRB, 42 Cal4th 850 (Cal Supreme No S144753, Dec 24, 2007, rehearing denied Feb 20, 2008). Most other states have declined to follow Pruneyard. Recent examples: Riemers v. GK Devel, 2007 WL 2746895 (USDC ND No 2:06-cv-97, Sep 20, 2007) (neither the US nor the North Dakota constitution makes a shopping mall a public forum); Kings Mall v. Wenk, 839 NYS2d 313 (NY AppDiv July 5, 2007) (mall owner did not infringe free speech rights by prohibiting persons from entering the mall to protest war in Iraq.) For a listing of states which have followed Pruneyard, and those which have declined to do so, see Cross v. State, 2004 WL 1535606 (TX App - El Paso No 08-03-00283-CR, July 8, 2004.)

VA hospital: Political activist was denied permission to conduct voter registration drive at VA hospital brought facial and "as applied" challenges to the federal administrative rule (38 CFR. § 1.218(a)(14)), which prohibits visitors to VA property from engaging in "demonstrations," including "partisan activities," unless authorized by the head of the facility involved. Held: in the first opinion, the Federal Circuit rejected all of his claims. Upon rehearing, the same court explained why the rule does not confer "unbridled discretion." The VA hospital’s mission is to provide medical and other social services to veterans; this is incompatible with using its property as public or dedicated public forum. The restriction on "partisan activities" by "visitors" is reasonable and viewpoint neutral; the regulation gives enough specific examples of disruptive demonstrations to guide the administrator’s discretion. The facial challenge is rejected; the "as applied" challenge remains pending in the trial court. Preminger v. Secy of Veterans Affairs, 498 F3d 1265 (Fed Cir No 2007-7008, Aug 17, 2007), __ F3d __, 2008 WL 482591 (Feb 25, 2008).

School walkway: Street preacher wore a sandwich board with a religious message and positioned himself on city sidewalk near school bus exit area, offering students religious literature and "a free pass to heaven." School principal directed him to stay away from students when buses were unloading. He challenged his conviction for second degree criminal trespass. Held: The purpose of the walkway is to give the students a route from their buses to the school; it is not a thoroughfare, and it is not a forum. His preaching could have interfered with the intended use of the property. The principal had the authority to exclude him, and did not violate his rights by doing so. State of Oregon v. Carr, 215 OrApp 306, 170 P3d 563 (OR App No D045702M, Oct 3, 2007).

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Contact Info:

The Sign Regulation / Public Forum Bulletin is published by Randal R. Morrison, member of the State Bar of California, Sabine & Morrison Attorneys, P.O. Box 531518, San Diego CA 92153-1518. Email: rrmatty@yahoo.com. Website: www.signlaw.com .

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This newsletter is published for informational purposes only, and does not constitute legal advice. If you have a legal question related to sign regulation or public forum, contact an attorney qualified in those fields. Receipt of, or reading of, this newsletter, does not form an attorney - client relationship.

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