Massage parlors are not a recent American phenomenon. They were a pervasive and, to many, a troublesome phenomenon during the "winning of the West."' In 1897, the Supreme Court determined that one advertisement by women inviting men to their "Baths" and "Massage" rooms was too obscene to be printed. In recent years there has been a sudden increase of interest in and concern about massage parlors. This note examines the most prevalent legal problems generated by the regulation of massage parlors: the relationship between the police power and massage parlor establishments, the constitutional concerns of equal protection and substantive due process and the various means used in regulating these establishments.

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