Hastings Communications and Entertainment Law Journal


Steven Saxton


In Metromedia v. San Diego III, the California Supreme Court laid to rest San Diego's billboard ordinance, rejecting guidelines set forth by the United States Supreme Court for curing the ordinance's constitutional defects. This note examines the reasons for the California court's decision. The author analyzes the various uses of "content neutrality" in first amendment adjudication, and traces the influence of content neutrality principles on the development of commercial speech doctrine. In turn,this analysis is applied to the Metromedia cases to explain the inconsistencies among them.