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    PENN ADVERTISING v MAYOR AND CITY COUNCIL OF BALTIMORE

    PUBLISHED

    UNITED STATES COURT OF APPEALS

    FOR THE FOURTH CIRCUIT

    PENN ADVERTISING OF BALTIMORE,

    INCORPORATED,

    Plaintiff-Appellant,

    v.

    MAYOR AND CITY COUNCIL OF

    BALTIMORE, A Municipal

    Corporation; KURT L. SCHMOKE, in

    his official capacity as Mayor of

    Baltimore City; DAVID TANNER, in

    his official capacity as the General

    Superintendent of Zoning

    Administration and Enforcement of

    Baltimore City,

    No. 94-2141

    Defendants-Appellees.

    THE AMERICAN ADVERTISING

    FEDERATION; THE AMERICAN

    ASSOCIATION OF ADVERTISING

    AGENCIES; THE ASSOCIATION OF

    NATIONAL ADVERTISERS,

    INCORPORATED; THE OUTDOOR

    ADVERTISING ASSOCIATION OF

    AMERICA, INCORPORATED;

    WASHINGTON LEGAL FOUNDATION;

    THE CITY OF CINCINNATI, OHIO; THE

    MARYLAND CONGRESS OF PARENTS &

    TEACHERS, INCORPORATED;

    THE COALITION FOR BEAUTIFUL

    NEIGHBORHOODS; BALTIMORE CITY

    WIDE LIQUOR COALITION FOR BETTER

    LAWS AND REGULATIONS; CITY AND

    COUNTY OF SAN FRANCISCO; CITY OF

    SAN JOSE,

    Amici Curiae.

    Appeal from the United States District Court

    for the District of Maryland, at Baltimore.

    Herbert F. Murray, Senior District Judge.

    (CA-94-877-HM)

    Argued: March 6, 1995

    Decided: August 31, 1995

    Before NIEMEYER and HAMILTON, Circuit Judges,

    and BUTZNER, Senior Circuit Judge.

    _________________________________________________________________

    Affirmed by published opinion. Judge Niemeyer wrote the opinion,

    in which Judge Hamilton and Senior Judge Butzner joined.

    _________________________________________________________________

    COUNSEL

    ARGUED: Eric Michael Rubin, RUBIN, WINSTON, DIERCKS,

    HARRIS & COOKE, Washington, D.C., for Appellant. Burton Harry

    Levin, Assistant Solicitor, Baltimore, Maryland, for Appellees. ON

    BRIEF: Walter E. Diercks, Jeffrey Harris, RUBIN, WINSTON,

    DIERCKS, HARRIS & COOKE, Washington, D.C., for Appellant.

    Neal M. Janey, City Solicitor, Sandra R. Gutman, Associate Solicitor,

    DEPARTMENT OF LAW, Baltimore, Maryland, for Appellees.

    Richard E. Wiley, Lawrence W. Secrest, III, Daniel E. Troy, Luis

    de la Torre, Frank Winston, Jr., WILEY, REIN & FIELDING, Wash-

    ington, D.C., for Amici Curiae American Advertising Federation, et

    al. Mark S. Yurick, Senior Assistant City Solicitor, OFFICE OF THE

    CITY SOLICITOR, Cincinnati, Ohio, for Amicus Curiae City of Cin-

    cinnati. Daniel J. Popeo, David A. Price, WASHINGTON LEGAL

    FOUNDATION, Washington, D.C., for Amicus Curiae Washington

    Legal Foundation. Donald Garner, Professor of Law, SOUTHERN

    ILLINOIS UNIVERSITY, Carbondale, Illinois; THE MARYLAND

    CONGRESS OF PARENTS & TEACHERS, INC., Baltimore, Mary-

    land, for Amicus Curiae Maryland Congress. Christopher J. Fritz,

    Julie Ellen Squire, Thomas C. Dame, GALLAGHER, EVELIUS &

    JONES, Baltimore, Maryland, for Amici Curiae Coalition for Beauti-

    ful Neighborhoods, et al. Louise H. Renne, City Attorney, Dannis

    Aftergut, Chief Assistant City Attorney, Barbara Solomon, Deputy

    City Attorney, John Cooper, Deputy City Attorney, San Francisco,

    California, for Amicus Curiae San Francisco; Joan Gallo, City At-

    torney, George Rios, Assistant City Attorney, San Jose, California,

    for Amicus Curiae San Jose.

    _________________________________________________________________

    OPINION

    NIEMEYER, Circuit Judge:

    We must decide in this case (1) whether Ordinance 307 enacted by

    the Mayor and City Council of Baltimore, Maryland, prohibiting the

    placement of stationary, outdoor "advertising that advertises ciga-

    rettes" in certain areas of the City, is preempted by the Federal Ciga-

    rette Labeling and Advertising Act or by Maryland statutes

    prohibiting the sale of cigarettes to minors or the possession of ciga-

    rettes by minors; and (2) whether that ordinance violates the First and

    Fourteenth Amendment protections of commercial speech. The dis-

    trict court, granting Baltimore's motion for summary judgment, ruled

    that neither federal nor state law preempts the operation of Balti-

    more's ordinance and that the ordinance is a permissible regulation of

    commercial speech under the four-part test announced in Central

    Hudson Gas and Elec. Corp. v. Public Serv. Comm'n of N.Y. , 447

    U.S. 557 (1980). We affirm.

    I

    Even before 1994, it was illegal in Maryland for any person to pur-

    chase cigarettes for, or sell them to, "any individual under the age of

    18 years." Md. Ann. Code art. 27, § 404 (1992). In 1994, Maryland

    also enacted statutes, effective October 1, 1994, prohibiting minors

    from using or possessing "any tobacco product." Md. Ann. Code art.

    27, §§ 404 & 405A (Supp. 1994). A few months earlier, in April

    1994, the Mayor and City Council of Baltimore (collectively "Balti-

    more"), in a further effort to reduce the illegal consumption of ciga-

    rettes by minors, enacted Ordinance 307. The ordinance prohibits the

    placement of any sign that "advertises cigarettes in a publicly visible

    location," i.e. on "outdoor billboards, sides of building[s], and free

    standing signboards." 1   The prohibition contained in Ordinance 307

    parallels the scope and language of Baltimore City Ordinance 288,

    enacted in January 1994, which regulates the advertising of alcoholic

    beverages. Thus, the prohibition against cigarette advertising in Ordi-

    nance 307 mirrors Ordinance 288's exceptions permitting such adver-

    tising on buses, taxicabs, commercial vehicles used to transport

    cigarettes, and signs at businesses licensed to sell cigarettes, including

    professional sports stadiums. As with Ordinance 288, Ordinance 307

    also contains an exception permitting such advertising in certain com-

    mercially and industrially zoned areas of the City.

    Before enacting the ordinance, the Baltimore City Council con-

    ducted public hearings, receiving testimony and previously-conducted

    studies detailing the correlation between cigarette advertising and the

    consumption of cigarettes by minors. The City Council found, as

    expressed in the preamble to Ordinance 307, that cigarettes are the

    most heavily advertised product in America and that"there is specific

    and convincing evidence that tobacco advertising plays a significant

    role in stimulating illegal consumption of cigarettes by minors." It

    referred specifically to 10 studies and articles supporting that position.

    The City Council also relied on the 1992 Maryland Adolescent Drug

    Survey conducted by the Maryland Department of Education to sup-

    port its conclusion that cigarettes are the second most commonly

    abused substance by Maryland adolescents, with approximately 42%

    of twelfth graders and 11% of sixth graders having smoked cigarettes

    in the previous 12 months. The City Council emphasized further that

    75% of twelfth graders had smoked cigarettes before the age of 15.

    It noted that cigarettes constitute a "gateway drug" for Maryland stu-

    dents, as they are often the first drug used by adolescents and "ap-

    pear[ ] to ´open the door' for use of other harder drugs at a later date."

    Therefore, to reduce the illegal consumption of cigarettes by minors,

    the City Council concluded that it would be reasonable to restrict the

    placement of publicly visible cigarette advertisements in the City.

    On April 6, 1994, the date on which Ordinance 307 became effec-

    tive, Penn Advertising of Baltimore, Inc., filed suit in federal court to

    enjoin the ordinance's enforcement and to obtain a declaratory judg-

    ment (1) that the ordinance is preempted by § 5(b) of the Federal Cig-

    arette Labeling and Advertising Act, 15 U.S.C. § 1334(b), and by

    Maryland statutes regulating the sale of cigarettes, and (2) that the

    ordinance violates the First and Fourteenth Amendments. Penn

    Advertising, which leases land from private property owners, main-

    tains outdoor signs on those locations, and rents them to its custom-

    ers, filed suit to protect its business of placing cigarette

    advertisements on outdoor signs located in Baltimore.

    With its complaint, Penn Advertising filed a motion for a prelimi-

    nary injunction to enjoin, pending litigation, enforcement of Ordi-

    nance 307. In response, Baltimore filed a motion to dismiss or, in the

    alternative, for summary judgment. While Penn Advertising obtained

    some discovery following the filing of these motions, it desired to

    conduct more discovery and thus filed a motion to extend the time to

    file its opposition to Baltimore's summary judgment motion. The dis-

    trict court denied the motion and established a briefing schedule for

    the parties. The court also entered an order staying enforcement of the

    ordinance.

    On August 15, 1994, the district court filed a memorandum opinion

    granting Baltimore's motion for summary judgment. The district

    court concluded that Ordinance 307 is preempted neither by the Fed-

    eral Cigarette Labeling and Advertising Act nor by Maryland state

    law. On the First Amendment issue, the court concluded that Ordi-

    nance 307 satisfied all four prongs of the Central Hudson test and was

    thus a permissible regulation of commercial speech. This appeal

    followed. 2  

    II

    We address first a preliminary contention that the district court

    abused its discretion in refusing to extend Penn Advertising's time to

    conduct discovery and respond to Baltimore's motion for summary

    judgment. Penn Advertising argues that the court granted summary

    judgment "before there had even been adequate time for Penn Adver-

    tising to assemble a full evidentiary record and after denying Penn

    Advertising's motion for leave to take discovery for the purpose of

    further establishing the disputed factual record."

    While the district court granted Penn Advertising a short extension

    to respond to the motion for summary judgment, it did not generally

    open up the case for discovery before ruling on the issues. It con-

    cluded that such discovery was not necessary in view of the nature of

    the issues presented. The district court stated that the questions pres-

    ented are "legal questions ripe for decision" because the case concerns

    "a facial attack on the legal sufficiency of an ordinance." Penn Adver-

    tising of Baltimore, Inc. v. Mayor and City Council of Baltimore , 862

    F. Supp. 1402, 1405 (D. Md. 1994). Penn Advertising nonetheless

    was able to oppose the motion for summary judgment with affidavits,

    various studies, and samples of advertising, and has failed to identify

    any further materials or theories which it desired, but was unable, to

    present to the district court.

    We agree that the issues presented to the district court were ques-

    tions of law which could be resolved without further development of

    the factual record. The preemption issue rests on a legal interpretation

    of the federal statute which allegedly preempts the ordinance. As the

    Supreme Court noted in Cipollone v. Liggett Group, Inc. , 112 S. Ct.

    2608, 2618 (1992), "the pre-emptive scope of the 1965 Act and the

    1969 Act is governed entirely by the express language in § 5 of each

    Act." Our interpretation of the instant issue as involving solely a

    question of law is also consistent with the procedural posture of the

    Cipollone case before the Supreme Court, i.e. on review of a motion

    under Federal Rule of Civil Procedure 12(f) to strike the preemption

    defense as a matter of law.

    Furthermore, we agree with the district court that a facial challenge

    to an ordinance restricting commercial speech may be resolved as a

    question of law when the government meets the burden placed on it

    by Central Hudson . We decided the same question in the companion

    case of Anheuser-Busch, Inc. v. Schmoke , ___ F.3d ___, No. 94-1431

    (4th Cir. Aug. 31, 1995), where we stated:

    [I]n response to a facial challenge to a regulation of com-

    mercial speech, the burden falls on the government to justify

    its legislative action, but it does not demand that the govern-

    ment canvass every conceivable situation in which some

    member of the public may be affected atypically by the stat-

    ute. And the court's inquiry is limited to consideration of the

    ordinance on its face against the background of the govern-

    ment's objective and the prospect of the ordinance's general

    effect. If it appears to the court that the legislative body

    could reasonably have believed, based on data, studies, his-

    tory, or common sense, that the legislation would directly

    advance a substantial governmental interest, the govern-

    ment's burden of justifying it is met.

    ___ F.3d at ___, slip op. at 10. The determinative question in review-

    ing a facial challenge to an ordinance thus is whether the legislative

    body acted with the objectively reasonable belief that the means it

    selected fit the objective sought. The issue is not whether the substan-

    tive findings on which it relied are incontrovertibly true. As we

    explained in Anheuser-Busch :

    While a party [facially] challenging an ordinance can point

    to other factors not considered by the legislature to demon-

    strate that the legislature acted irrationally, it cannot subject

    legislative findings themselves to judicial review under a

    clearly erroneous standard or otherwise. To do so would

    ignore the structural separation between legislative bodies

    and courts and would improperly subordinate one branch to

    the other.

    ___ F.3d ___, slip op. at 11.

    Since the burden of justifying the ordinance falls on the govern-

    ment and it may carry this burden by pointing to legislative facts,

    studies, history, or common sense, an understanding of the ordi-

    nance's factual impact on particular parties is not necessary to the

    inquiry. Id . at 10-12. Accordingly, we conclude that the district court

    did not abuse its discretion in this case by ruling on the summary

    judgment motion without allowing further discovery.

    III

    Penn Advertising contends that Ordinance 307 is void because Bal-

    timore's authority to enact such a measure was preempted by § 5(b)

    of the Federal Cigarette Labeling and Advertising Act, which pro-

    vides:

    No requirement or prohibition based on smoking and health

    shall be imposed under State law with respect to the adver-

    tising or promotion of any cigarettes the packages of which

    are labeled in conformity with the provisions of this chapter.

    15 U.S.C. § 1334(b). That Act mandates that one of several specified

    warning messages be placed on each package of cigarettes and pro-

    hibits cigarette advertising on television and radio. See 15 U.S.C.

    §§ 1331-1340. Penn Advertising argues that since Ordinance 307's

    prohibition of cigarette advertising is "based on smoking and health,"

    it is preempted by the federal statute. Its argument rests entirely on

    the analysis of § 5(b) of the federal act conducted by the Supreme

    Court in Cipollone v. Liggett Group, Inc.

    The lawsuit in Cipollone was predicated on the smoking-related

    death of Rose Cipollone, who began smoking in 1942 and died of

    lung cancer in 1984. Her son sought damages from cigarette manufac-

    turers, contending that cigarette smoke caused his mother's death. His

    suit, based on New Jersey common law, alleged common law claims

    involving design defects; failure to warn; breach of express warranty;

    fraudulent misrepresentation; conspiracy to defraud; and negligence

    in the manner in which cigarettes were tested, researched, sold, pro-

    moted and advertised. On the cigarette manufacturers' contention that

    Cipollone's claims were preempted by the Federal Cigarette Labeling

    and Advertising Act, the Supreme Court held:

    [T]he 1969 Act pre-empts petitioner's claims based on a

    failure to warn and the neutralization of federally mandated

    warnings to the extent that those claims rely on omissions

    or inclusions in respondents' advertising or promotions; the

    1969 Act does not pre-empt petitioner's claims based on

    express warranty, intentional fraud and misrepresentation, or

    conspiracy.

    112 S. Ct. at 2625. To reach this conclusion, the Court conducted a

    count-by-count analysis of the common law claims to determine

    whether each claim implicated duties to warn or to label in connection

    with smoking and health. The Court explained:

    [W]e must fairly but--in light of the strong presumption

    against pre-emption--narrowly construe the precise lan-

    guage of § 5(b) and we must look to each of petitioner's

    common law claims to determine whether it is in fact pre-

    empted.

    Id . at 2621. To sort out those claims that were preempted, the Court

    stated:

    The central inquiry in each case is straightforward: we ask

    whether the legal duty that is the predicate of the common

    law damages action constitutes a "requirement or prohibi-

    tion based on smoking and health . . . imposed under state

    law with respect to . . . advertising or promotion," giving

    that clause a fair but narrow reading.

    Id . at 2621 (emphasis added). The Court went on to clarify that the

    appropriate inquiry is "not whether a claim challenges the ´propriety'

    of advertising and promotion, but whether the claim would require the

    imposition under state law of a requirement or prohibition based on

    smoking and health with respect to advertising or promotion." Id . at

    2622. See also Vango Media, Inc. v. City of New York , 34 F.3d 68,

    73-74 (2d Cir. 1994) (holding that Federal Cigarette Labeling and

    Advertising Act preempts ordinance requiring city-licensed facilities

    to display one message addressing the dangers of smoking for every

    four tobacco advertisements displayed).

    Applying the methodology described in Cipollone to Ordinance

    307, we conclude that the Federal Cigarette Labeling and Advertising

    Act does not preempt the ordinance. Ordinance 307 limits only the

    location of signs that advertise cigarettes, but it does not address the

    content of such advertisements. The ordinance neither imposes a duty

    nor relieves a burden on cigarette advertisers based on smoking and

    health . Moreover, the ordinance does not limit the ability of cigarette

    manufacturers to advertise generally in the media. The regulation sim-

    ply restricts the location of cigarette-advertising signs, irrespective of

    the nature of the message communicated. A regulation with such a

    general relationship to cigarette smoking--in contrast to a specific

    advertising "prohibition based on smoking and health"--is not pre-

    empted by the Federal Cigarette Labeling and Advertising Act. Were

    the preemption provision to be interpreted so broadly, the Supreme

    Court in Cipollone could not have allowed the continued prosecution

    of common law claims for breach of express warranty, misrepresenta-

    tion, intentional fraud, and conspiracy--all of which relate generally

    to the effects on health of promoting the sale of cigarettes. See

    Cipollone , 112 S. Ct. at 2621-25.

    For similar reasons, we conclude that the Maryland statutes prohib-

    iting the sale of cigarettes to minors and the use and possession of

    cigarettes by minors, see , e.g. , Md. Ann. Code art. 27, §§ 404 & 405A

    (supp. 1994), and Md. Ann. Code, Business Regulation art., § 16-101

    et seq ., do not preempt the City's ordinance. Penn Advertising argues

    that Ordinance 307 is invalid because it impliedly was preempted by

    these state statutes under the doctrine of "preemption by implication"

    set forth in Allied Vending, Inc. v. Bowie , 332 Md. 279 (1993). The

    court in Allied Vending explained that there may be times when "´the

    legislature may so forcibly express its intent to occupy a specific field

    of regulation that the acceptance of the doctrine of preemption by

    occupation is compelled.'" Id . at 298 (quoting Mayor and City Coun-

    cil of Baltimore v. Sitnick , 254 Md. 303, 323 (1969)). The reasoning

    of Allied Vending , however, lends little support to Penn Advertising's

    claim. We can find nothing in §§ 404 and 405A of Article 27 or

    § 16-101 et seq . of the Business Regulation Article that indicates an

    attempt by the Maryland legislature to preempt the field of cigarette

    advertising. Moreover, Ordinance 307, which only limits the place

    and manner of cigarette advertising, is not in conflict with the state

    provisions prohibiting their sale to minors. For the reasons stated

    above, as well as those articulated by the district court in its well-

    reasoned opinion, see Penn Advertising , 862 F. Supp. at 1415-20, we

    reject the contention that Ordinance 307 is preempted and therefore

    null and void.

    IV

    Finally, Penn Advertising contends that Ordinance 307 is an imper-

    missible regulation of commercial speech under the four-prong

    scheme announced in Central Hudson . As that case explains, in order

    for commercial speech to be entitled to any First Amendment protec-

    tion, the speech must first concern lawful activity and not be mislead-

    ing. See Central Hudson , 447 U.S. at 563 . If the commercial speech

    meets those threshold criteria, a state may nevertheless regulate it if

    (2) the state is able to assert a substantial interest in support of the

    regulation; (3) the state demonstrates that the regulation "directly

    advances the governmental interest asserted"; and (4) the regulation

    is not "more extensive than is necessary" to serve the interest. Id . at

    566.

    The governmental interest asserted in this case is to promote com-

    pliance with the state prohibition of the sale of cigarettes to minors.

    The district court concluded that the ordinance also furthers the obvi-

    ous public policy underlying such a prohibition,"which is to prevent

    the purchase, and thus the consumption, of cigarettes by minors."

    Penn Advertising , 862 F. Supp. at 1406. In the context of the current

    public concern over the dangers of cigarette consumption by minors,

    there can be little opposition to the assertion that the City's objective

    in reducing cigarette consumption by minors constitutes a substantial

    public interest.

    The principal dispute in this case centers on Central Hudson 's third

    and fourth prongs which question whether Ordinance 307 directly

    advances Baltimore's stated public interest in reducing minors' ciga-

    rette consumption and whether the ordinance is not more extensive

    than necessary to serve that interest, i.e. whether it is "narrowly

    drawn." The inquiry under these two prongs of Central Hudson

    involves consideration of the "fit" between the City's ends and the

    means chosen to accomplish them. See United States v. Edge Broad-

    casting Co. , 113 S. Ct. 2696, 2705 (1993); Posadas de Puerto Rico

    Assocs. v. Tourism Co. , 478 U.S. 328, 341 (1986).

    These same issues were resolved in favor of Baltimore in the

    related case of Anheuser-Busch, Inc. v. Schmoke , ___ F.3d ___, No.

    94-1431 (4th Cir. Aug. 31, 1995). In Anheuser-Busch , the City relied

    on numerous studies that linked alcohol advertising to underage

    drinking to meet Central Hudson 's third prong. In response to

    Anheuser-Busch's challenge to those conclusions, we stated:

    There is a logical nexus between the City's objective and the

    means it selected for achieving that objective, and it is not

    necessary, in satisfying Central Hudson 's third prong, to

    prove conclusively that the correlation in fact exists, or that

    the steps undertaken will solve the problem. If that were

    required, communities could never initiate even minor steps

    to address their problems, for they could never be assured

    of the success of their efforts. The proper standard for

    approval must involve an assessment of the reasonableness

    of the legislature's belief that the means it selected will

    advance its ends. Under that approach, we conclude that

    Baltimore has met its burden of satisfying the third prong of

    Central Hudson .

    ___ F.3d at ___, slip op. at 15-16. Similarly, in our examination of

    whether the advertising regulation was narrowly tailored to meet

    Central Hudson 's fourth prong, we concluded in Anheuser-Busch :

    If there were some less restrictive means of screening out-

    door advertising from minors, or of reducing the area of bill-

    board regulation in a manner that would have it focus more

    efficiently on reaching minors, the City would have to con-

    sider those alternatives. But it is not an acceptable response

    to the approach taken by the City of limiting advertising

    exposure to say that the City must abandon altogether an

    approach that directly advances its goal. In the face of a

    problem as significant as that which the City seeks to

    address, the City must be given some reasonable latitude.

    ___ F.3d at ___, slip. op. at 19.

    For the reasons advanced in Anheuser-Busch , we conclude here

    that, while the fit between the City's objectives and the means

    selected to achieve them may not be perfect, it nevertheless falls well

    within the range tolerated by the First Amendment for the regulation

    of commercial speech.

    For the foregoing reasons, we affirm the judgment of the district

    court.

    AFFIRMED

    FOOTNOTES


    1  
    The core provision of Ordinance 307 provides:

    Cigarette advertisements. No person may place any sign, poster,

    placard, device, graphic display, or other form of advertising that

    advertises cigarettes in a publicly visible location. In this section

    "publicly visible location" includes outdoor billboards, sides of

    building[s], and free standing signboards.

    Baltimore City Code, Art. 30 (zoning), § 10.0-1(I). By its terms, the ordi-

    nance became effective April 6, 1994.


    2  
    Amici curiae briefs were received in this appeal from the American

    Advertising Federation, the American Association of Advertising Agen-

    cies, the Association of National Advertisers, Inc., the Outdoor Advertis-

    ing Association of America, Inc., the Washington Legal Foundation, the

    Maryland Congress of Parents & Teachers, Inc., the Coalition for Beauti-

    ful Neighborhoods, the Baltimore City Wide Liquor Coalition for Better

    Laws and Regulations, the City of Cincinnati, the City and County of

    San Francisco, and the City of San Jose.

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