First, this Court Docket could overrule the City of Renton/Hill content-neutral justification rule as being inconsistent with the Reed rule of strict scrutiny. First, as documented in Half B.1 supra, decrease courts have disagreed on whether City of Renton is still good regulation after Reed, and how a lot of their prior case legislation must be revisited in mild of Reed. Thus, the secondary effects doctrine was developed in a context of deference to local governments' traditional land-use authority, the place the secondary effects have been ones stemming from physical proximity. This is according to this Courtroom's deferential angle towards zoning, see, e.g., Village of Euclid v. Ambler Realty Co., 272 U.S. 365 (1926). 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