HomeMy WebLinkAboutMINUTES - 10271998 - D9 TO: BEARD OF SUPERVISORS
FROM: William Walker, M.D., Health Services Director Contra
by Wendel Brunner, M.D.,Public Health Director Costa
DATE: October 22, 1998 County
SUBJECT: TOBACCO FREE YOUTH ORDINANCE
SPECIFIC REQUEST($)OR RECOMMENDATION(S)&BACKGROUND AND JUSTIFICATION
RECOMMENDATION:
1. Introduce the attached ordinance drafted by County Counsel restricting tobacco advertising in areas where
youth frequent, and tobacco promotion to youth, waive reading, and set December 8, 1998 for adoption of
ordinance and supporting findings.
2. Direct the Health Services Department to prepare detailed alternative proposals for licensing or registering
tobacco retailers and report to the Family&Human Services Committee on the possible alternative approaches.
BACKGROUND:
In April 1997 the Tobacco Prevention Coalition responded to the Board of Supervisors bequest to make Tobacco Free
Youth a public policy priority. On July 15, 1997 the Internal Operations Committee directed the Health Services
Department to prepare a comprehensive draft model ordinance for consideration.', Working with the Tobacco
Prevention Coalition,the Health Services Department presented a comprehensive compendium of provisions restricting
youth access to tobacco to the Internal Operations Committee on December 16, 1997.
On February 1.0, 1998 the model ordinance was presented to the full Board. The Board then directed the Health
Services Department, working with County Counsel, to report on various options the Board could pursue, with an
analysis of the legal risks associated with different options. On May 19, 1998 the Health Services Department
presented the Board of Supervisors with five policy recommendations:
I. Ban on all outdoor tobacco advertising within 1,600 feet of schools and playgrounds.
2. Ban tobacco advertising in the windows of retail establishments within 1,600 feet of schools and playgrounds.
3. Ban the sale and distribution to minors of promotional items identified with tobacco brands.
4. Ban self-service tobacco displays inside retail stores.
5. Require a license or permit to sell tobacco products retail.
CONTINUED ON ATTACHMENT: YES X SIGNATURE:
RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE
APPROVE OTHER
SIGNA E S
ACTION OF BOARD ON OCTOBER 27, 1998 APPROVED AS RECOMMENDED X OTHER X
SES ADDENDUM FOR BOARD ACTION
VOTE OF SUPERVISORS
I HEREBY CERTIFY THAT THIS IS A TRUE
UNANIMOUS (ABSENT ) AND CORRECT COPY OF AN ACTION TAKEN
AYES: II 'III IV I NOES: V AND ENTERED ON THE MINUTES OF THE BOARD
ABSENT: ABSTAIN: D= OF SUPERVISORS ON THE DATE SHOWN,
Contact Person:
CC: Health Services Administration ATTESTED t7.= 27, 1
PHIL ATCHELOR,CLERK OF THE BOARD OF
SUPERVIS SAND COUNTYADMINISTRATOR
BY DEPUTY
2
On September 15, 1998 the Health Department returned to the Board of Supervisors with detailed language embodying
the above principles, including several options for a licensing provision for tobacco retailers.
On both May 19 and September 15 there was extensive testimony from members of the community including over 40
high school youth. The youth in particular testified about the tobacco advertising and promotion directed at underage
youth and the ease with which minors can obtain tobacco and tobacco products. The youth brought many photographs
of tobacco advertising in the community specifically directed at youth,and photographs',of self-service tobacco displays
associated with candy, ice cream, and toys which were attractive to youth and children.
The Board of Supervisors indicated both on May 18 and on September 15 their general support for provisions 1
through 4,but there was no clear consensus about the appropriate approach for the licensing issue. As a result of those
discussions, we are presenting specific language for adoption worked out with County Counsel that embodies the
Recommendations 1 through 4 above. We are suggesting that the Health Services Department bring the licensing
provisions to the Family &Human Services Committee for further discussion and direction to staff.
CONSEQUENCE CE O NEGATIVE ACTS:
Minors and children would have greater exposure to tobacco advertising and promotion,much of which is specifically
directed at youth. Minors and youth would have greater access to tobacco products through retailers and self-service
displays.
FISCAL IMPACT:
There are no financial implications for the County General Fund anticipated.
WW:WB:ah
Attachment
ADDENDUM
D.9
OCTOBER 2'7, 2998
On this date,the Board of Supervisors considered an ordinance drafted by County
Counsel restricting tobacco advertising in areas where youth frequent, and tobacco
promotion to youth.
Public testimony was received from the following persons.
Peter Muller, 7 Bel Air Drive, Orinda;
Lisa Bautista Rivera, Tobacco Industry Gets Hammered By Teens (TIGHT), Pittsburg;
Jon Higgins, 4287 Brentwood Circle, Concord;
Ashley Brandle, 5017 Fray Ave, Richmond;
Joe Escher, R.J. Reynolds Tobacco, 3 Embarcadero Center, San Francisco;
David Gutierrez, TIGHT, 27 Seaview Drive, Bay Point,
Jesse Quinonez, 1825 Hayes Court, Concord;
Nancy Andrews, Smoke Free USA, 1125 B Arnold Drive,Martinez;
Danny Knopofe&Daniel May, 11116 Cape Cod Way, Concord;
Ayanna Autrey, TIGHT;
Monica Cervantez, TIGHT, 88 Breaker Drive, Bay Point;
DeLois Basnett, American Lung Association, 105 Astrid, Pleasant Hill,
Maria Saucedo, TIGHT, 2101 Mandarin Way,Antioch;
Somphone Silapasay, TIGHT, 160 Corte Linda, Pittsburg;
Joel White, Tobacco Prevention Coalition, American Cancer Society, 318 Ridgestone
Court, Walnut Creek.
After receiving testimony,the Board took the following actions:
1. ACCEPTED the report from the Health Services Director on the proposed
ordinance restricting the advertisement,promotion and sale of tobacco products in
the County;
2. DIREC'T'ED the Health Services Director to prepare detailed alternative proposals
for licensing or registering tobacco retailers, and to report to the Family and
Human Services Committee on the possible alternative approaches;
3. AMENDED section 445-2.004 (4)of the proposed ordinance, inserting the words
"or exempted",the sentence to read" On billboard signs covered or exempted by
voluntary agreements between Contra Costa County and billboard companies in
effect on the effective date of this ordinance";
4. INTRODUCED Ordinance 98-43, Restriction of Tobacco Advertising and
Promotion,as amended; WAIVED the reading; and SET November 3 1998 for
adoption.
FRECEIVED
COUNTY COUNSEL'S OFFICE
CONTRA COSTA COUNTY
MARTINEZ,CALIFORNIA CLERK BOARD OF SUPERVISORS
DONl'I�A C 57'A O,
Date: October 23, 1998 Item D.9
To: Board of Supervisors
From: j Victor J. Westman, County Counsel
By: Diana J. Silver, Deputy County Cour
Re: Draft Ordinance Restricting Tobacco Advertising and Promotion: Board Agenda,
October 27, 1998, Item D.9
Pursuant to a request received October 22, 1998,this office has revised the draft ordinance
restricting tobacco advertising in publicly visible locations within 1600 feet of specified areas
(schools,playgrounds, etc.),prohibiting distribution of tobacco-related promotional items to minors,
and banning self-service displays of tobacco products. As requested, it does not contain a tobacco
retailers licensing provision.
Our views with respect to the restrictions on tobacco advertising remain the same as those
expressed in the attached memos dated February 5, 1998 (see pages 3-6) and May 13, 1998,
(paragraphs #1 and#3).
DJSIds
cc: Wendel Brunner, M.D., Public Health Services
Charlotte Dickson, Tobacco Prevention Project
H AD$1L V\MEMMtcsbadv.wpd
ORDINANCE NO. 98-
(RESTRICTION OF TOBACCO ADVERTISING AND PROMOTION)
The Contra Costa County Board of Supervisors ordains as follows (omitting the parenthetical
footnotes from the official text of the enacted or amended provisions of the County Ordinance
Code): [Gov. C. § 25120]
SECTION I. SUMMARY. This ordinance restricts the advertising and promotion of tobacco
products and distribution of tobacco-related promotional products to minors. [§25129.]
SECTION II. Division 445 is added to the County Ordinance Code, to read:
Division 445
RESTRICTION ON TOBACCO ADVERTISING AND PROMOTION
Chapters:
445- 2 Restrictions on Tobacco Advertising
445-4 Distribution of Promotional Items to Minors
445-6 Self-service Displays
445-8 Administration&Enforcement
Chapter 445-2
Restrictions on Tobacco Advertising
445-2.002 Definitions. The following words and phrases,whenever used in this
division, shall be construed as hereafter set out,unless it is apparent that they have a different
meaning:
(1) "Advertising display sign"means a sign, signboard,billboard,poster,
free-standing sign,balloon, pennant, or banner, that is temporarily or permanently placed on or
affixed to the ground, the sidewalk, a pole or post, a fence, or a building, or is displayed in the
windows or doors of a commercial establishment, and that is used to advertise or promote
products.
(2) "County Administrator"means the Contra Costa County Administrator
or his or her designee.
ORDINANCE NO. 98- I
(3)"Mobile Billboard7 means any sign,placard, billboard, or other
display advertisement upon or affixed to a vehicle which is used primarily to advertise a product
illegal to sell to minors,when the supporting vehicle or trailer is parked within a public right of
way or on private property and visible to the public for a duration of time and in a manner which
clearly indicates that the sign is for advertising products illegal to sell to miners or which carry a
specific brand name, logo, indicia of a product illegal to sell to minors. For the purposes of this
division, mobile billboard shall not include any advertisement on the side of a van, truck, or
other vehicle which is primarily used for the transportation of goods or products.
(4) "Person"means any individual, firm, partnership, cooperative
association, private corporation, personal representative, receiver, trustee, assignee or other legal
entity.
(5) "Promote" or"promotion"means a display of any logo,brand name,
character, graphics, colors, scenes, designs, or recognizable color or pattern of colors, or any
other indicia or product identification with, or similar to, or identifiable with, those used for any
particular brand of tobacco product.
(6) "Publicly Visible Location"means any outdoor location that is visible
from any street, sidewalk, or other public thoroughfare, or any location inside a commercial
establishment immediately adjacent to a window or door where such location is visible from any
street, sidewalk, or other public thoroughfare.
(7) "Tobacco product" shall mean any substance containing tobacco leaf,
including but not limited to cigarettes, cigars,pipes,tobacco, snuff, chewing tobacco and
dipping tobacco.
(8) "Tobacco retailer"shall mean any person who sells,offers for sale, or
exchanges or offers to exchange for any form of consideration, tobacco, tobacco products or
tobacco paraphernalia; "tobacco retailing" shall mean the doing of any of these things. (Ord.
98- , § 2.)
445-2.004 Restriction on Advertising of Tobacco Products. No person shall
place or maintain, or cause or allow to be placed or maintained, in any manner any advertising or
promotion of cigarettes or tobacco products on an advertising display sign in a publicly visible
location within 1600 feet of the perimeter of an elementary or secondary school,public
playground or playground area in a public park(e.g., a public park with equipment such as
swings and seesaws, baseball diamonds or basketball courts). (Ord. 98-_, § 2.)
445-2.006. Exceptions. This section shall not apply to advertising or promotions
for tobacco products:
(1) Located inside a commercial establishment, unless such advertising
ORDINANCE NO. 98- 2
display sign or promotion is attached to, affixed to, leaning against, or otherwise in contact with
any window or door in such a manner that it is visible from a street, sidewalk or other public
thoroughfare;
(2) On vehicles, other than mobile billboards;
(3) On any sign located inside or immediately outside a commercial
establishment if the sign provides notice that the establishment sells tobacco products, so long as
the sign does not promote any brand of tobacco product;
(4)On billboard signs covered by voluntary agreements between Contra
Costa County and billboard companies in effect on the effective date of this ordinance;
(5) On tobacco product packaging. (Ord. 98-____, § 2.)
Chapter 445-4
Distribution of Promotional Items to Minors
445-4.002 Sate and Distribution of Tobacco-related Promotional Items. No
manufacturer, distributor, or retailer of tobacco products may market, license,distribute, sell, or
cause to be marketed, licensed, distributed or sold any item(other than tobacco products) or
service to a minor,which bears the brand name (alone or in conjunction with any other word),
logo, symbol,motto, selling message,recognizable color or pattern of colors, or any other
indicia or product identification identical with, or similar to,or identifiable with, those used for
any brand of tobacco product. (Ord. 98-_____, § 2.)
Chapter 445-6
Self-Service Displays
445-6.002 Prohibition. It shall be unlawful for any person or tobacco retailer
within the unincorporated areas of the County to sell, permit to be sold, offer for sale, or display
for sale any tobacco product by means of self-service display, rack, counter-top or shelf that
allows self-service sales for any tobacco product other than vendor-assisted sales. (Ord. 98-_,
§ 2.)
445-6.004 Vendor Assistance. All tobacco products shall be offered for sale
exclusively by means of vendor/employee assistance, with tobacco products in a locked case
requiring employee assistance to retrieve the tobacco products. (Ord. 98- , § 2.)
ORDINANCE NO. 98- 3
Chapter 445-8
Administration and Implementation
445-8.002 General. Except as otherwise provided,this division shall be
administered by the County Administrator. The County Administrator may develop guidelines,
as appropriate,to ensure implementation of this division. (Ord. 98--, §2.)
445-8.004 Violations. (a) The County Administrator will review and, if
determined appropriate, act upon any written complaint submitted by any private citizen or
County officer or employee concerning any advertising or promotion prohibited by this division
in a timely manner. The County Administrator may serve written notice requiring correction of
any violation of this section upon the person responsible for the advertising display sign or
promotion or self-service display prohibited by this division. Any notice issued shall specify a
date by which the violation shall be corrected.
(b) Failure to correct specified violations after written notice has been served
may result in enforcement by any remedy allowed by this code(See chapters 14-6 and 14-8). If
three notices requiring the correction of any violation of this ordinance (whether the violation
involves the same or different displays or promotions) are served on the same person within a
thirty day period, an enforcement action may be initiated against that person without the serving
of another notice, if the additional violation occurs within ninety days of the serving of the third
notice.
(c) Each separate display of tobacco advertising or promotion prohibited by this
ordinance shall be considered a separate violation.
(d) For purposes of determining liability of persons, firms or corporations,
controlling franchises or business operations in multiple locations, each individual franchise or
business location shall be deemed a separate entity. (Ord. 98-_____, § 2.)
445-8.006 Intent as to Additional Legal Restrictions and Remedies. Nothing
in this division is intended to alter the obligations or restrictions that apply to any person under
any other law governing signs, billboards,tobacco advertising or any other matter covered by
this division. The remedies set forth in this division are not exclusive. If any action prohibited
by this division is also unlawful under any other law,the penalties and remedies under such
other laws may be pursued in addition to those provided in this division. (Ord. 98-_, § 2.)
445-8.008 Disclaimers. By prohibiting the advertising or promotion of tobacco
products in outdoor or publicly visible locations, prohibiting the distribution of tobacco-related
promotional items and self-service displays of tobacco products, the County of Contra Costa is
only promoting the general welfare. It is not assuming, nor is it imposing on its officers and
employees, an obligation for breach of which it is liable in money damages to any person who
ORDINANCE NO. 98- 4
claims that such breach proximately caused injury. (Ord. 98-_, § 2.)
SECTION 111. EFFECTIVE DATE. This ordinance shall become operative six months after
the date it is finally adopted. Within 15 days after passage,this ordinance shall be published
once with the names of supervisors voting for and against it in the ,
a newspaper published in this County. [§§ 25123 & 25124.1
PASSED on ,by the following vote:
AYES:
NOES:
ABSENT:
ABSTAIN:
ATTEST: PHIL BATCHELOR, Clerk of the
Board and County Administrator
By:
Deputy Board Chair
DJSJjh
H:iGROUMSTAMTOBORD WPD
ORDINANCE NO. 98- 5
COUNTY COUNSEL'S OFFICE
CONTRA COSTA COUNTY
MARTINEZ,CALIFORNIA
Date: May 13, 1998
To: William B. Walker, M.D., Director Health Services Dept.
Attn: Wendel Brunner, M.D., Public Health Director
From: Victor J. Westman, County Counsel
By: Diana J. Silver, Deputy County Counsel
Re: Proposed provisions in tobacco ordinance
This is in response to your memo to this office of May 12, 1998 regarding your proposed
recommendations to the Board of Supervisors concerning tobacco advertising restrictions and
regulation of tobacco retailers. We understand you will not be asking this office to review the actual
recommendations and staff report(Board Order) before it is presented to the Board of Supervisors due
to time constraints. As we don't have the specific Board Order to review, our comments are
necessarily general, in response to the general concepts you list in your memo. Our comments could
be different after a review of specific proposed provisions.
We address the four items in the order listed in your May 12, 1998 memo:
1. Ban on all outdoor tobacco advertising within 1640 feet of schools,playgrounds and
libraries. As we discussed in our meeting April 20,1998, this proposed ban includes advertising that
is located inside commercial stores but is visible from the outside. As we commented in our memo of
February 5, 1998 to the Board of Supervisors (see copy attached), we have concerns that such a
regulation may be deemed"content-based" and vulnerable to challenge as discussed on pages five and
six of our February 5, 1998 memo. We are aware that San Francisco has adopted a similar restriction
but that ordinance will not become effective until July 16, 1998. The San Francisco ordinance does
not impose a ban on advertising within a specific distance from schools, etc. because of the proximity
of schools to stores and other reasons related to the compactness of the city. Again,we urge you to
determine what the actual effect of imposing a specified-distance ban would be on outdoor advertising
(including inside-store advertising visible to the outside)because, as we stated in our February 5,
1998, memo, you need to determine whether such a restriction will result in an outright ban on tobacco
advertising (see February 5, 1998,memo,p.5). As we said in our February 5, 1998, memo, it does not
appear from the information furnished that black and white or"tombstone"advertising would save the
restriction on advertising inside commercial establishments from a successful challenge on First
Wendel Brunner, M.D. page 2
Tobacco Ordinance proposals May 13, 1998
Amendment grounds (see February 5, 1998,memo, footnote 6).'
We note two other matters with respect to this proposal: mobile billboards and motor
vehicles are included in the ban,and there is no exclusion for billboards. As the ordinance will be
effective only in the unincorporated area, it would be difficult to enforce the tobacco advertising ban
on moving vehicles or mobile billboards, particularly when located on public highways. We note that
both San Francisco and Compton ordinances except vehicles from the ban. Secondly, it has not been
clear that the Board of Supervisors wants billboards included in any proposed tobacco advertising
restrictions in view of the billboard agreements with the outdoor advertising companies.'
2. Ban on self-service displays inside retail stores. We understand that a number of
jurisdictions in.California have enacted similar bans. When we receive your specific proposal in the
form of a draft ordinance, we would like you also to furnish us with ordinances in other local
jurisdictions, e.g., San Francisco, with their history, including litigation, if any, so that we may
compare provisions in your draft ordinance with other ordinances.
3. Ban tobacco advertising in the windows of retail establishments within 1600 feet of
schools. See discussion in#1 above. We are not aware of any such "point of purchase"advertising
restriction in California or anywhere in the United States (other than a federal district court ruling in
Washington state) that has yet successfully withstood legal challenge. As noted above,the San
Francisco ordinance containing similar restrictions becomes effective July 16, 1998.
4. Requirement of a License for Sale of Tobacco Products. You have given us no details
on this proposal. You do indicate,however,that such a license would be subject to suspension or
revocation, or would not be issued at all if the retailer fails to comply with state law, including Penal
Code §308,which prohibits sale of tobacco products to minors. It is difficult to comment on this
general proposal without any specific draft language to review. We note,however,that such a
provision may be subject to a successful preemption challenge if the suspension,revocation or refusal
to issue the license for selling tobacco to minors were found by a court to constitute a duplication of
state law or an imposition of additional penalties to those set forth in Penal Code §308. On the other
hand, if licenses were withheld or suspended for violating express terms of the license,e.g.,
prohibition on self-service displays, one could argue that there was no preemption, only enforcement
of the terms or conditions of the license. In drafting license provisions,you may wish to include as a
i it is possible that studies supporting a finding that minors are not attracted to black and
white advertising might be helpful in countering such a First Amendment challenge. Mere
speculation is not enough(Edenfield v. Fane, 507 U.S. 761 (1993); see February 5, 1998 memo,p.
3).
Z It is interesting to note that San Francisco exempts from the ban billboards within 660 feet
of a highway .
Wendel Brunner,M.D. page 3
Tobacco Ordinance proposals May 13, 1998
condition for obtaining a license,that the tobacco retailer agree not to have self-service displays of
tobacco products. Other conditions could be imposed on the license which were designed to
discourage minors from violating state law, including Penal Code section 308. As you know, one
California court has ruled that discouraging the illegal sale of tobacco to minors is not preempted(see
Brava Tending v. City of Rancho Mirage (1993) 16 Cal. App. 4t'383,412, discussed on p.10 of 2/5/98
memo).
We are informed by Edith Cabuslay of the San Mateo Tobacco Prevention Program that San
Mateo County has not yet adopted the licensing ordinance you attached to your memo. We note that
the San Mateo draft licensing ordinance, if adopted,would not be effective untilSeptember 1, 1998.
We look forward to receiving your proposed draft ordinance for our review and comments
at your earliest opportunity.
DJS/ds
cc: Members, Board of Supervisors
H:\DSILV\MEMOS\TOBPROV.WPD
COUNTY COUNSELS OFFICE
CONTRA COSTA COUNTY
MARTINEZ,CALIFORNIA
Date: February 5, 1998
To: Board of Supervisors
From: Victor J. Westman, County Counsel
By: Diana J. Silver, Deputy County Counsel'
Re: Provisions of proposed Model Tobacco-Free Youth Ordinance
Summary
On January 20, 1998,the Board of Supervisors directed this office to perform an analysis of
two sections of the model ordinance which are aimed at controlling demand by minors for tobacco
products (II.A.3: Regulation of Tobacco Advertising) and at controlling supply;to minors of tobacco
products (ILB.3: Conditional Land Use Permits for Sale of Tobacco Products by Retail Outlets) and to
advise the Board of any constitutional issues raised by these provisions. We have reviewed the draft
ordinance, materials submitted to this office by the Health Services Department, including comments
received by that department regarding the ordinance and relevant case law, including the four-part test
for First Amendment constitutionality established by the United States Supreme Court in the Central
Hudson case'. In essence, our conclusions are as follows:
(1) We have concerns that some of the provisions regulating tobacco,advertising(§II.A.3)
may be too broad and/or vague to survive a constitutional challenge on First Amendment grounds. For
this reason, it may be difficult to meet the fourth prong of the Central Hudson test, i.e., that the
regulation is not more extensive than necessary to serve a substantial governmental interest.
(2) We believe that if applied,a challenge may be made with respect to the proposed
requirement that retailers obtain conditional use permits before they are allowed to begin selling
tobacco products. It may be argued that such regulation constitutes a denial of equal protection of the
laws and/or constitutes a deprivation of due process under the U.S. Constitution.
(3)As for businesses that already sell tobacco products, the standards set forth in the draft
ordinance are subject to challenge on the grounds of over breadth and vagueness (due process). The
"Performance Standards" in the draft ordinance which, if violated, may cause a person to lose their
"Deemed Approved" status do not amount to nuisance standards. A prior legal',non-conforming use
generally cannot be taken away unless a nuisance exists or unless the use is extended or enlarged.
Another challenge to a conditional use permit requirement could be made on the basis that one may
'Central Hudson Gas & Elec. a Public Serv. Comm'n, 447 U.S. 557 (1980).
Board of Supervisors page 2
Model Tobacco-Free Ordinance February 5, 1998
lose"deemed approved"status by selling tobacco products to minors and that the County cannot
impose additional penalties for violations which are fully covered under by state law, i.e.,that such a
County provision would be preempted by state law(Penal Code §308)2. Our analysis follows.
Section II.A.3 : Regulation of Tobacco Advertising'
In 1980, the United States Supreme Court established a four part testfor assessing the
constitutionality of restrictions on commercial speech:
"At the outset,we must determine whether the expression is protected by the First
Amendment. For commercial speech to come within that provision, it at least
must concern lawful activity and not be misleading. Next we ask whether the
asserted governmental interest is substantial. If both inquiries yield positive
answers, we must determine whether the regulation directly advances the
governmental interest asserted, and whether it is not more extensive than is
necessary to serve that Interest."(Central Hudson, supra,447 U.S. at;566).
On the face of the proposed ordinance, it appears that the four types of advertising sought to
be regulated concern lawful activity and are not misleading.' Thus,presumably this advertising is
protected by the First Amendment to the U.S. Constitution(first prong of Central Hudson test). Next,
we must ask whether the County can demonstrate a substantial government interest which the County
seeks to achieve by regulating these four types of advertising. The apparent interest of the County, as
2This office has not been asked to inquire into non-constitutional issues.' In addition to the
issue of statutory preemption with respect to conditional use permits,there are other areas of concern
with respect to the proposed conditional use permit provisions: several areas of conflict with existing
standards for land use permits under the Contra Costa County Ordinance Code(see C.C.C.Ord Code
§26-2.2008); vagueness in standards and procedure for obtaining a conditional use permit and
problems in satisfying"nuisance"standards with respect to regulating existing retailers of tobacco
products. The issues involved are complex; this report is merely an overview and is intended as a
timely response to the Board's direction and an attempt to address the concerns expressed by the
Board at the January 20, 1998 hearing.
'The four types of advertising proposed to be regulated in the ordinance are: 1-outdoor
advertising of tobacco products (prohibited within 2500 feet of"areas where minors frequent"), 2-
tobacco advertising on windows and inside retail establishments (prohibited within 2500 feet of
"areas where minors frequent" if can be seen from the street, exception for black and white
"tombstone"advertising), 3-retail window advertising for any product(limited to 10%of window
area),4-tobacco advertising on County-owned property (prohibited).
Board of Supervisors page 3
Model Tobacco-Free Ordinance February 5, 1998
stated in the proposed findings and purpose of the ordinance(§H.A.I)4 is to promote compliance with
state law which prohibits the sale of tobacco products to minors(Pen. Code §308, copy of statute
attached for the Board's convenience) and to further the obvious public policy underlying this
prohibition, which is to prevent the purchase and consumption of tobacco products by minors. This
certainly appears to constitute a sufficiently substantial interest for purposes of satisfying the second
prong of the Central Hudson test(see Penn Advertising of Baltimore, Inc., v. The Mayor and City
Council of Baltimore, et al.,101 F. 3d 332 (4'Cir.)(1996)).
Next, we must ask if the proposed regulation directly advances this substantial interest(third
prong of Central Hudson test). if the answer if yes, is the regulation narrowly tailored to serve the
County's asserted substantial interest or are the proposed ordinance provisions more extensive than
necessary to serve the interest(fourth prong of Central Hudson test)?
1-Prohibition on outdoor tobacco advertising(e.g.,billboards, sides of buildings,free
standing signboards,etc.)within 2500 feet of`areas where minors frequent."(§ILA.3.a.1.)
Restrictions on outdoor advertising of tobacco products have been found directly to advance
the local government's substantial interest (as defined above) (see Penn.Adv. ofBaltimore v. Mayor
and City Council of Baltimore 141 F. 3d 332,333 (4t'Cir. 1996), affirming its earlier ruling, cited as 63
F.3d 1318 (4'Cir. 1995)). In apparent recognition of this, California legislation effective January 1,
1998 prohibits outdoor billboard advertising of tobacco products within 1,400 feet of schools and
allows more stringent regulation by local governments (Bus. & Prof Code §§22958, 22961). Several
California cities (Oakland, Long Beach, Compton, San Francisco) and Los Angeles County have
enacted or are considering enacting similar prohibitions. There has been judicial recognition in the
Ninth Circuit(which includes this county) that"advertising increases consumption of the product or
service being advertised." (Cal-Almond, Inc. v. UnitedStates Dep't ofAgric. 14 F.3d 429,439 (9'Cir.
1993)). The County also must be able to demonstrate, however, that there is an immediate connection
between advertising and demand among minors. Further, the United States Supreme Court has stated
that mere speculation or conjecture by the County does not satisfy the third prong of the Central
Hudson test:
"a governmental body seeking to sustain a restriction on
commercial speech must demonstrate that the harms it recites are
real and that its restrictions will in fact alleviate them to a material
degree." (Edenfield v. Fane, 507 U.S. 761 (1993)).
If it can be shown that the demand for cigarettes and other tobacco products among minors
decreases as a result of decreased advertising, the County's policy of preventing acts that encourage
'lf some form of this model ordinance is ultimately adopted by the Board of Supervisors, we
suggest that the Findings be set out in a separate document from the codified version of the
ordinance.
Board of Supervisors page 4
Model Tobacco-Free Ordinance February 5, 1998
conduct violating Penal Code section 308 (illegal sales to minors) is advanced and passes the third
prong of the Central Hudson test.
As presently drafted,however,these provisions may be challenged as more extensive than
necessary to serve the asserted substantial governmental interest under the fourth prong of the Central
Hudson test. The United States Supreme Court has explained this fourth prong of the test as follows:
the means adopted to advance the substantial governmental interest must be"...a means narrowly
tailored to achieve the desired objective." (Board of Trustees v. Fox 492 U.S. 469,480 (1989)).
The restrictions on tobacco advertising apply to a 2500-foot radius of areas where minors
frequent. Such areas are defined in the draft ordinance as
"any area, facility,or location that provides special services for,or
predominantly serves,people under the age of 18 years of age,
including any nursery,kindergarten, elementary,middle or high
school; licensed child care center;playground; recreational
facility; arcade; and library."(§II.A.2. Definitions,1.)
The examples provided in the definition are not exclusive, merely inclusive.' Thus,a
"facility"could be a fast food restaurant,a bowling alley, a toy store,etc. What is most troubling,
however,is the term itself; "areas where minors frequent"is so broad and vague as to be subject to
constitutional challenge on due process grounds as well as not meeting the fourth prong of the Central
Hudson test.
If the Board desires to adopt this type of ordinance, it may wish to consider adoption of a
Baltimore-type ordinance,which the Fourth Circuit found to have met the Central Hudson test,
including the fourth prang, i.e., that the restrictions were not more extensive than necessary to serve
the asserted substantial interest. The Baltimore ordinance banned outdoor advertising of tobacco
products in certain zones of the city. When a specified distance,e.g., 2500 feet,is restricted,however,
the provision is vulnerable to challenge on the ground that it constitutes an outright ban on the
restricted activity(see C.R. of Rialto, Inc. v. City of Rialto, 964 F. Supp. 1401 (C.D. Cal. 1997), adult
oriented businesses permitted in commercial and industrial zones but prohibited within 1000 feet of
residential zones or certain specified uses found to constitute total ban on adult oriented businesses and
therefore,unconstitutional).
If the Board desires to proceed with a specified restricted area, it would be advisable to
have a study done to ensure that the restriction will not result in an outright ban of an activity that is
generally constitutionally protected free expression. That is, the County must be able to demonstrate
5 W note that such areas are not confined to unincorporated areas of the County; thus, the
"area where minors frequent" might include areas within a city with the prohibition extending 2500
feet in any direction, including unincorporated area subject to the ordinance.
Board of Supervisors lege 5
Model Tobacco-Free Ordinance February 5, 1998
that the restriction is not so broad as to constitute an outright ban on tobacco advertising. The greater
the distance proscribed, the higher the risk of a constitutional challenge claiming it amounts to an
outright ban on tobacco advertising. Thus,the vagueness of the term"areas where minors frequent"
coupled with a 2500-foot prohibition on outdoor tobacco advertising, is probably a restriction that is
more extensive than necessary to meet the County's asserted interest in preventing purchase and
consumption of tobacco products by minors and does not meet the fourth prong of the Central Hudson
test.
Finally,we suggest that in connection with the preparation of any final version of an
ordinance restricting outdoor billboard advertising consideration be given to exempting current
contracts with billboard companies from the restrictions imposed by a subsequently adopted ordinance.
2-Prohibition on tobacco advertising inside a retail establishment or on windows if can
be seen from the street within 2,500 feet of an area where minors frequent(f§II.A.3.a.2. and
II.A.3.c and d.).
The above analysis of the third prong of the Central Hudson test also applies to these
proposed restrictions. It is this office's opinion,however, that this regulation would be more difficult
to defend,because these provisions appear to be more"content-based"rather than merely a restriction
on the time,place, and manner of the tobacco product advertising.' A content based restriction
receives a much higher level of scrutiny by the courts than does a"time,place and manner"restriction.
Thus,the County would have a heavier burden to justify this"Point of Purchase"advertising
restriction than in the case of outdoor advertising restrictions discussed above(see Desert Outdoor
Advertising, Inc., v. City ofMoreno Valley 103 F.3d 814(911 Cir. 1996): billboard restrictions imposed
by California city found unconstitutional for being content based)).
We are not aware of any case law which has upheld the type of restriction proposed here.
It is our view that this type of restriction would be quite vulnerable to challenge,because it would be
argued that the restriction dues not directly advance the County's substantial interest in preventing the
purchase and consumption of tobacco products by minors (see 44 Liquormart, Inc., et al v. Rhode
Island et al., U.S.__ _(1996)).
In 44 Liquormart, the United States Supreme Court ruled that Rhode Island's ban on
advertisement of retail liquor prices except for price tags or signs displayed with the merchandise
within licensed premises and not visible from the street did not advance directly the state's interest in
temperance(third prong) and was more extensive than necessary(fourth prong)). In view of this case
slt is our opinion that the exception for black and white advertising, so-called"tombstone
advertising,"will not save this regulation from probably being successfully challenged as
unconstitutional under the First Amendment to the U.S. Constitution as an impermissible content
based restriction on commercial free speech.
Board of Supervisors page 6
Model Tobacco-Free Ordinance February',5, 1998
and a likely successful challenge that this type of regulation would be preempted under the Federal
Cigarette Labeling and Advertising Act(FCLAA)(15 U.S.C. §§1331-1340),because it would be
considered to be a"prohibition based on smoking and health...imposed under state law with respect to
the advertising or promotion of any cigarettes" (15 U.S.C. §1334(b))we have serious concerns about
the constitutionality of this proposed regulation.
In addition,we have a number of concerns with the scope of the regulation. As discussed
above, it may be difficult to satisfy the fourth prong of the Central Hudson test,',i.e.,that the ordinance
provisions are narrowly tailored to serve the County's asserted substantial interest when the ban is of
such a wide area(2504 feet) and when the ban extends to any area `frequented"by minors. This is a
vague term and subject to challenge as much more extensive than necessary and,thus,not in
compliance with the fourth prong of the Central Hudson test.
3-Limitations on retail window advertising for any product (II.A.3a.2.c)).
This provision prohibits signs posted in a window of a retail, commercial or industrial
establishment from obscuring more than ten percent of the total transparent area of the window. This
provision expressly"applies to all advertising, not just advertising,far tobacco products."' We have
found no support for such a provision in this ordinance which purports to discourage illegal sale of
tobacco products to minors. It is difficult to discern how this provision would directly advance the
County's substantial interest in preventing the sale of tobacco products to minors. Thus, it is
unnecessary to reach the fourth prong of the Central Hudson test(whether it is more extensive than
necessary to serve that interest). This provision appears to be unrelated to the ordinance under
consideration.
4-Prohibition of Tobacco Advertising on County owned property(§II.A.3.b.)
The County, in its proprietary capacity, can control advertising on property in which it has
sufficient proprietary interests. The County,however, cannot impair existing contracts with lessees or
lessors or other persons or entities with whom the County has entered into contractual relationships.
Where current contracts exist, they would have to be amended to reflect such a restriction.
If an owner of property leased to the County has retained proprietary rights sufficient to
permit such advertising, the County would not be able to interfere with such rights. But to the extent
the County has sufficient proprietary rights in the subject property, the Board can adopt an order,
resolution, or ordinance prohibiting such advertising or the same result could be accomplished through
issuance of an administrative bulletin by the County Administrator.
'The exception in commercial and industrially zoned areas where the advertisements `pare
not within 2500 feet of areas where minors frequent or visible in aforementioned;places"dues
nothing to advance the County's asserted interest.( see §11A.3.a.3.).
Board of Supervisors page 7
Model Tobacco-Free Ordinance February 5, 1998
As for property which is"operated"by the County, it is unclear if this refers to real or
personal property. Without clarification of this term it is not clear how this provision as currently
drafted could meet the fourth prong of the Central Hudson test because, by its ambiguity, it is more
extensive than necessary to serve the County's asserted substantial interest in preventing tobacco
product sales to minors.. This provision could be rewritten, however, to be narrowly tailored as
constitutionally mandated. It is possible that as revised, it could be added to the current tobacco
ordinance(see C.C.C. Ord. Code Division 440, Tobacco Products).
Section II.B.3: Conditional Use Permits for Sale of Tobacco Products
We are not aware of any city or county ordinances in California which regulate the sale of
tobacco products through a conditional(land)use permit(LUP)process. Under the California
Constitution, the County may"make and enforce within its limits all local,police,sanitary, and other
ordinances and regulations not in conflict with general laws."(Cal.Const. Art XI, §7). The County
may establish zoning and other related land use regulations under its police power granted under the
California Constitution as long as there is some rational basis to support such regulation(Miller v.
Board of Public Works (1925) 195 Cal. 477, 490;Associated Home Builders, etc., Inc. v. City of
Livermore(1976) 18 Cal. 3d 582, 609).
The power and authority of counties to grant LUPs, if reasonable, is a valid exercise of the
police power(Cal. Const. Art. Xi,§7; Topanga Assn.for a Scenic Community v. County of Los Angeles
(1974) 11 C.3d 506, 511). In addition, there is specific statutory authority for counties to hear and
decide applications for LUPs (and other permits) when the zoning ordinance so provides and
establishes criteria for determining such matters (Gov. Code §65901). This County has provided such
procedures by zoning ordinances (see C.C.C. Ord. Code §26-2.1204 (2): zoning administrator hears
and initially decides requests for LUPs; C.C.C. Ord. Code Art. 26-2.20: procedures and standards for
LUPs; C.C.C. Ord. Code §26-2.2008: standards and required findings for issuance of LUPs). A
general welfare standard is typical, and generally, sufficient(see C.C.C. Ord. Code §26-2.2008(1);
Hawkins v. County of Marin(1976) 54 Cal. App. 3d 586). Most zoning ordinances, including this
County's, declare violations of the ordinance to be public nuisances subject to abatement proceedings
(C.C.C. Ord. Code §14-6.204; see generally, Longtin, California Land Use, 2d Ed. (1987) §10.61(6),
p.940).
Several recent nuisance abatement ordinances containing an LUP requirement for retailers
of alcoholic beverages (to be consumed off-site) have been upheld as administrative mechanisms for
controlling and abating nuisances (Suzuki v. City of Los Angeles (1996)44 Cal. App. 41'263; City of
Oakland v. Superior Court(1996) 45 Cal. App. 4" 740). Unlike zoning ordinances, a nuisance
abatement ordinance may be applied retroactively; however, the County's police power to proscribe
nuisances is more limited than its zoning power. An"undoubted menace to public health, safety or
morals"must be shown to establish a nuisance (Suzuki v. City of Los Angeles (1996) 44 Cal. App. 4'
263, 275-276).
Board of Supervisors lege 8
Model Tobacco-Free Ordinance February 5, 1998
The LUP provisions of the draft model tobacco ordinance appear to be derived in large part
from the"Deemed Approved Performance Standards" set forth in Oakland ordinance aimed at
addressing public nuisance problems associated with certain liquor stores in certain areas of the city
(see City of Oakland v. Superior Court,supra at 747). The existing business activity(in Oakland,
liquor stores;here,tobacco retailers)is deemed to be an approved commercial activity as long as the
merchant conforms to certain standards and posts a notice containing the"performance standards." If
there is a complaint the standards have been violated, an administrative hearing must be conducted.
Hearing and appeal procedures and enforcement methods are not specified in the draft ordinance now
being considered by this Board.
New businesses which are established after the effective date of the ordinance and existing
businesses which"substantially change its mode or character of operation''are required to obtain an
LUP.1 Although the County has wide discretion under its police power to regulate new businesses by
zoning ordinances and may apply the general welfare standard in determining whether to grant an LUP
for certain types of businesses as specified in its zoning ordinance, there must be a rational basis for
distinguishing between retailers of one type of consumer product from retailers of other types of
consumer products. Lack of a rational basis raises the risk of attack as a denial of equal protection of
the laws under the U.S. Constitution(see Elysium Inst., Inc. v. County of Los Angeles (1991)232 Cal.
App. 3d 408,426,427).
In the draft model ordinance now being considered by the Board, four factors are to be
considered in making the determination whether to grant the LUP.' The factors are general and
somewhat vague. As stated in the discussion of the proposed regulation of outdoor advertising,we
have concerns that the term"areas where minors frequent" (§ II.B.3d.1) may be subjected to a
constitutional challenge on due process grounds as being too vague and overly broad. For example,
one of the factors to be considered is whether the sale of tobacco products is"appropriate...given the
percentage of patrons likely to be minors or the nature of other products to be carried." This"factor"
is extremely vague and therefore, is vulnerable to a constitutional challenge on due process and equal
protection grounds. That is, a tobacco retailer would argue that there is no way of knowing where
minors are likely to frequent, or whether the sale of tobacco products is"appropriate"and therefore,
that this factor is too vague to be applied with any precision and will result in arbitrary denials of use
permits (due process claim.). Secondly,the tobacco retailer would argue there is no rational basis for
"This conflicts with existing County Code provisions governing prior legal nonconforming
uses (see C.C.C. Ord Code §82-8.006; LUP required only if existing legal nonconfoming use is
extended or enlarged). The quoted language in the draft ordinance appears to have been taken from
Business and Professions Code §23790(alcoholic beverage licenses) and is inapplicable here.
9The County officer, e.g., zoning administrator, to conduct the hearing isnot identified; nor
is there any reference to existing County Code procedures for LUP hearings, factors to be considered
in granting an LUP and appeal provisions(see C.C. C.Ord Code Chapter 26-2).
Board of Supervisors page 9
Model Tobacco-Free Ordinance February 5, 1998
forcing him or her to go through an expensive time-consuming LUP process when other retailers of
consumer products are not required to do so (equal protection claim).
These constitutional challenges may not be successful as applied to new tobacco retailers,
given the wide discretion the county has under its police power. As discussed above,the County may
be able to impose an LUP requirement on new tobacco retailers ( i.e.,with only prospective effect)
using a general welfare standard if there is a rational basis for requiring tobaccos retailers to obtain
LUPs.
As for existing businesses which"substantially change its mode of operation,"although the
factors listed in the draft ordinance might meet a general welfare standard for purposes of regulating
new tobacco retailers, a tobacco retailer legally in business before the effective date of the ordinance
generally cannot lose the right to conduct a tobacco product retail business unless nuisance conditions
exist on the premises. As discussed above, the factors set forth in the draft ordinance("Performance
Standards")may meet a general welfare standard but do not amount to a nuisance : "an undoubted
menace to public health, safety or morals"(see Suzuki v. City of Los Angeles (1996)44 Cal. App. 41
263, 275-276).
In addition, as stated above, a prior legal nonconforming use cannot be subjected to an LUP
requirement unless it expands or enlarges the use (Longtin, California Land Use, 2d Ed. (1987),Vol.
1, §3.80[4], p.609). Although there is generally no right to expand a nonconforming use, a person has
a fundamental vested right to continue operating an established business (Goat Hill Tavern v. City of
Costa Mesa (1992)6 Cal,App. 411 1519)). Therefore,without an expansion or enlargement of the use
or a demonstrated nuisance on the premises, an existing tobacco retailer generally could not be
deprived of the right to continue his or her business nor could he or she be legally required to obtain an
LUP for breaching one of the"Performance Standards" listed in the draft ordinance.
We note also that an applicant for an LUP has the"burden of proving by clear and
convincing evidence that the proposed use will not result in the sale or distribution of tobacco products
to minors, adversely affect the safety or welfare of the community, result in undue concentration of
tobacco retailers,or detrimentally affect nearby communities." (§II.B. 3e). This appears to be a very
difficult, if not impossible,burden of proof, given the far reaching and broad sweep of this
requirement. It also goes beyond the usual"substantial evidence" standard employed in malting LUP
decisions. Thus, the vagueness of the factors to be considered and the extremely heavy burden of
proof upon an applicant could result in a challenge based on denial of due process (deprivation of right
to conduct business of selling lawful tobacco products and without adequate notice and opportunity to
be heard: i.e., substantive and procedural due process claims)and denial of equal protection of the
laws by singling out tobacco retailers for special treatment and subjecting them to a time-consuming,
burdensome, and expensive LUP process which is not required for retailers of other products.
The Board directed this office to examine the constitutional issues involved in these two
sections of the draft ordinance. We feel we should point out, however, that the likeliest challenge to
Board of Supervisors page 10
Model Tobacco-Free Ordinance February 5, 1998
the proposed LUP process for tobacco retailers will be on the ground that this area of the law is
expressly preempted by state law. Penal Code §308. Penal Code §308 prohibits sales of tobacco
products to minors. It provides civil and criminal penalties (Pen. Code §308(a)). It expressly provides
that no city or county"shall adopt any ordinance inconsistent with this section." (Pen. Code §308(e)).
"An otherwise valid ordinance is preempted by state statute if the ordinance duplicates or
contradicts the statute, or if the ordinance enters into a field of regulation expressly or impliedly
reserved to the state."(Water Quality Assn. v County of Santa.Barbara (1995) 44 Cal. App. 4X'732,
741).
To the extent the LUP provisions in the draft ordinance establish penalties based on illegal
sale of tobacco products to minors,they would be subject to a preemption challenge. Pursuant to this
draft model ordinance, an existing business may lose its"deemed approved" status by selling tobacco
products to minors (see"Performance Standards" in §1I.B.3a.Lb)) or a new retailer(or existing
business that changes its mode of operation) will not be able to obtain an LUP if he or she cannot
prove by clear and convincing evidence that the proposed use will not result in the sale or distribution
of tobacco products to minors (see §II.B.3e), These are penalties for the sale of tobacco products to
minors which probably are preempted by Penal Code §308.'°
The Suzuki and City of Oakland cases discussed above, which required LUPs for new liquor
stores and those which lost their"deemed approved" status, survived preemption challenges because
they were based on the municipality's police power to control and abate nuisances. In the draft
ordinance now under consideration, the nuisance rationale may not be viable where the penalties are
imposed(and the use is denied or revoked) for illegal sale of tobacco to minors because the state has
fully occupied this field through Penal Code §308.
It is permissible to enact an ordinance which discourages activity made illegal by the state
through a licensing procedure as long as the ordinance is intended to discourage the activity proscribed
by state law and does not attempt to either expand or reduce the degree to which the particular activity
regulated by state law is criminally proscribed(Bravo Vending v. City vfRancho Mirage(1993) 16
Cal. App. 41383,412). In Bravo Vending, the city adopted an ordinance which required tobacco
retailers to obtain a license and prohibited sales of cigarettes through the use of a vending machine.
The court upheld the ordinance because it did not impose any penalties for sales of tobacco products to
minors and was therefore,not preempted by state law. The ordinance did not distinguish to whom
tobacco products could be sold(Id. at 403). The court found the purpose of the ordinance was to
regulate the business of selling cigarettes in order to make illegal purchases of cigarettes by minors
1OWe do not distinguishing between the draft ordinance provisions which duplicate state
statute and those which are inconsistent with state statute since both areas come within the
preemption doctrine(see e.g.,Suter v. City of Lafayette(1997) 57 Cal. App. 411 1109, 1123 (firearm
licensing requirements);Morehart v. County of Santa Barbara (1994) 7 Cal. 4"725,747).
............................................................................................1.1.111,
. ...................................................................................
..............................
Board of Supervisors page 11
Model Tobacco-Free Ordinance February 5, 1998
less likely by prohibiting the particular manner of sale most often used by minors (Id at 409).11
Accordingly, we conclude that the proposed LUP process, if adopted, could be challenged
as preempted by Penal Code §308, in addition to the possible due process and equal protection
constitutional attacks discussed above.
This office has received the attached comments from the Community Development
Department Director concerning the proposed ordinance. These comments are consistent with
comments submitted by several of the persons and entities who responded to the Health Services
Department's request for comments,especially concerning the difficulties associated with creating and
enforcing an LUP process for tobacco retailers, some of which are discussed above. In addition,Mr.
Barry advises that eight additional billboards would be impacted by adoption of the proposed
ordinance. Locations are included in his memorandum.
HADS1LV\MEM0S\T0BACC0.WPD
"The County currently requires that vending machines have certain licenses and be located
25 feet from any entry into the premises (C.C.C. Ord. Code §440-6.002).