Golden Gate University Law Review Volume 42 Article 9 Issue 1 Ninth Circuit Survey January 2012 Coyote Publishing, Inc. v. Miller: Blurring the Standards of Commercial and Noncommercial Speech Nicole E. Wolfe Follow this and additional works at: http://digitalcommons.law.ggu.edu/ggulrev Part of the Commercial Law Commons, and the Constitutional Law Commons Recommended Citation Nicole E. Wolfe, Coyote Publishing, Inc. v. Miller: Blurring the Standards of Commercial and Noncommercial Speech, 42 Golden Gate U. L. Rev. (2012). http://digitalcommons.law.ggu.edu/ggulrev/vol42/iss1/9 This Note is brought to you for free and open access by the Academic Journals at GGU Law Digital Commons. It has been accepted for inclusion in Golden Gate University Law Review by an authorized administrator of GGU Law Digital Commons. For more information, please contact
[email protected]. Wolfe: Coyote Publishing, Inc. v. Miller NOTE COYOTE PUBLISHING, INC. v. MILLER: BLURRING THE STANDARDS OF COMMERCIAL AND NONCOMMERCIAL SPEECH NICOLE E. WOLFE* It is not easy to describe the present position of legal opinion on advertising and free speech. Only a poet can capture the essence of chaos.1 INTRODUCTION Prostitution is regarded as one of the world’s oldest professions.2 While the sale of sexual services has been in existence for centuries, practically every state in the United States has enacted laws that fully prohibit it.3 The underlying purposes for creating such laws include * J.D. Candidate, May 2012, Golden Gate University School of Law, San Francisco, California; B.A. Political Science and Law, Societies and Justice, University of Washington, Seattle, Washington.