Renton, Washington was involved in a 1986 Supreme Court case regarding this issue. Often, erotic theatres have been forced to move to the outskirts of cities in order to protect real estate prices in city centers. Local governments commonly prohibit adult theatres from operating within a certain distance of residential areas, parks, churches and/or schools. Restrictions on adult theatres vary by region, and may be restricted by local and state regulations. In the 1980s, some theatre owners began forming chains to cut their costs, and, by 1989, the number of U.S erotic theatres had fallen below 250. In the 1970s, theatres shifted from showing 35-millimetre sexploitation films to more explicit 16-millimetre 'beaver' films. Small 'storefront' theatres with only a dozen seats sprang up, and by 1970, 750 pornographic theatres existed in the U.S. The O'Farrell Theatre in San Francisco, one of America's oldest and best known adult-entertainment establishments, opened as an adult movie theatre in 1969. In the late 1960s and early 1970s, they spread to the rest of the country.
In 1960 there existed about twenty theatres in the U.S. were in California, and showed 35-millimeter low-production-quality independently produced films. Adult movie theatres and peep shows on Montreal's St.
