OTR Media Group, Inc. v. City of New York
Opinion of the Court
The motion court correctly held that the subject advertising regulations that restrict outdoor advertising situated within view of arterial highways and public parks and impose substantial penalties for violations do not violate plaintiffs right to free speech under the New York State Constitution (see NY Const, art I, § 8). Contrary to plaintiffs contention, the New York State Constitution does not afford heightened free speech protections to commercial speech. Rather, our courts apply the four-part test articulated by the United States Supreme Court in Central Hudson Gas & Elec. Corp. v Public Serv. Comm’n of N.Y. (447 US 557 [1980]) to restrictions on commercial speech (see Matter of von Wiegen, 63 NY2d 163, 172-173 [1984], cert denied sub nom. Committee on Professional Stds. v von Weigen, 472 US 1007 [1985]; Willow Media, LLC v City of New York, 78 AD3d 596, 596 [2010]). Applying the Central Hudson test, we hold that the subject regulations are constitutional because they directly advance the stated governmental interests of promoting traffic safety and preserving aesthetics, and are narrowly tailored to achieve those interests.
We also find no merit to plaintiffs contention that the penalty schedule set forth in Administrative Code of the City of New York § 28-502.6 is discriminatory because it subjects OACs and non-OACs to different fines for the same conduct. Equal treatment of the two categories of business is not required because OACs and non-OACs are not similarly situated. Indeed, in contrast to OACs, non-OACs do not engage in, or hold themselves out as engaging in, the outdoor advertising business (see Administrative Code § 28-502.1). Furthermore, because the penalty schedule differentiates based on the type of entity that violates the regulations, rather than on the content of the advertisements, rational basis review, as opposed to strict scrutiny, applies (see Willow, 78 AD3d at 596). Here, it cannot be said that the disparate treatment is “so unrelated to the achievement of any combination of legitimate purposes” as to be irrational (Affronti v Crosson, 95 NY2d 713, 719 [2001], cert denied sub nom. Affronti v Lippman, 534 US 826 [2001], quoting Kimel v Florida Bd. of Regents, 528 US 62, 84 [2000]). Indeed, the record clearly establishes that increased penalties were necessary to deter violations by OACs in particular.
Contrary to plaintiffs contention, the New York City Charter does not prohibit the Environmental Control Board (ECB) from imposing fines that are greater than $25,000. Rather, it limits the ECB’s authority to enforce final orders of more than $25,000 without court proceedings (see NY City Charter § 1049-a [d] [1] [g]).
We have considered plaintiffs remaining contentions and find them unavailing. Concur—Tom, J.P., Saxe, DeGrasse, Freedman and Abdus-Salaam, JJ.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.