In the United States, a series of Supreme Court decisions in the 1960s (based on the First Amendment to the United States Constitution) generally legalized sex shops, while still allowing states and local jurisdictions to limit them through zoning.[citation needed] Zoning regulations often caused shops to be located either on the outskirts of town, or clumped into a single area, creating a type of red light district of adult stores and businesses. Into the 1980s, nearly all American sex shops were oriented to an almost entirely male clientele.[citation needed] Many included adult video arcades, and nearly all were designed so that their customers could not be seen from the street: they lacked windows, and the doors often involved an L-shaped turn so that people on the street could not see in.[citation needed] In addition, during the late 1980s and early 1990s, stores that also had theaters or arcades were sometimes closed by government order, citing the spread of AIDS as the motive.[15]

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