Big John's Billiards Inc. v. State of Nebraska et al.

A smoke-free law prohibited smoking in public places and places of employment, except for certain facilities, including: (1) certain guestrooms in hotels and lodging, (2) tobacco retail outlets, and (3) cigar bars.  A billiards hall challenged the law, because the law prohibited smoking in some places but not others, which could be considered discriminatory (here called "special legislation"). The court found that the similarity between guestrooms and private residences was sufficient to allow smoking.  By contrast, tobacco retail shops and cigar bars must be treated the same as other public places and work places under the law, so the exceptions allowing smoking there were unconstitutional.  The court also found that the smoke-free law was not a regulatory taking and did not impair contract rights.  The unconstitutional provisions were severable, so the rest of the smoke-free law was upheld.

Big John's Billiards, Inc. v. State of Nebraska et al., and Douglas County Health Dep't., 288 Neb. 938 (Aug. 29, 2014)

  • United States
  • Aug 29, 2014
  • Supreme Court of Nebraska
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Parties

Plaintiff Big John's Billiards, Inc., A Nebraska Corporation

Defendant

  • Douglas County Health Department
  • State of Nebraska

Legislation Cited

Nebraska Clean Indoor Air Act

Related Documents

Type of Litigation

Tobacco Control Topics

Substantive Issues

Type of Tobacco Product

"The exemption for cigar bars was not part of the Act as it was originally enacted. Instead, it was enacted by subsequent legislation in 2009. The Introducer’s Statement of Intent on the proposed bill specifically stated that the purpose of the exemption was “to provide protection for businesses currently operating in the state as ‘cigar bars.’” During debate, the senator who introduced the bill argued that cigar bars should be exempt from the Act because they existed for the purpose of allowing smoking. There is no substantial difference in circumstances between cigar bars and other public places or places of employment that justifies treating cigars bars differently. Indeed, the exemption is directly contrary to the purpose of the Act, which is to protect the public health by limiting exposure to secondhand smoke. The exemption in § 71-5730(4) for cigar bars is unconstitutional special legislation."
"We conclude that there is no difference in circumstances between tobacco retail outlets and all other public places and places of employment so as to justify the expediency of diverse legislation and that the exemption in § 71-5730(3) is therefore unconstitutional special legislation. The mere fact that tobacco retail outlets sell only tobacco products does not distinguish them in any substantial way from other public places or places of employment. And allowing patrons of such shops to smoke simply because it is convenient does not comport with the purpose of the Act, which is to protect the public and employees from the dangers of secondhand smoke."