Law School Case Brief
Allied Artists Pictures Corp. v. Rhodes - 496 F. Supp. 408 (S.D. Ohio 1980)
A court cannot strike down state laws, regulatory of business and industrial conditions, because they may be unwise, improvident, or out of harmony with a particular school of thought.
Plaintiffs major producers and distributors of motion pictures challenged the constitutionality of Ohio Rev. Code Ann. §§ 1333.05-1333.07, which prohibited blind bidding for licenses to show motion pictures in Ohio, and instead provided for open licensing against the Governor of Ohio. "Blind bidding" is a term used in the motion picture industry to describe the licensing of a motion picture to a theater owner without the owner's first viewing the picture. Citing the increasingly high costs of production and distribution of motion pictures together with the small cadre of extremely popular motion picture professionals, the plaintiffs contended their practices are entirely reasonable and necessary to the presentation of excellent and financially successful motion pictures. The plaintiffs also content that the Ohio Act violated the Due Process Clause of the Fourteenth Amendment, the First Amendment, the Commerce Clause, and the Supremacy Clause of the United States Constitution. The defendant filed a motion to dismiss the case for lack of jurisdiction and to abstain from exercising its jurisdiction.
Does the Ohio Act violate the Constitution?
The court found that the statute was a content-neutral economic regulation and that it served the state's legitimate interests in promoting widespread, competitive dissemination of information and in the maximization of financial return to its movie industry. The court also found that the statute did not unduly burden or discriminate against interstate commerce, because it did not stop the flow of films at Ohio's borders. Lastly, the court found that federal antitrust and copyright laws did not preempt the statute, because no direct conflict existed between them. The court also denied defendants motion to dismiss ruling it had jurisdiction over the matter.
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