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• K. Total Bans Whether a city has the power to totally ban pawnshops is unclear in the case law. It has been held that regulations so onerous as to amount to a prohibition of pawnshops is not permissible. See 54 Am. Jur. 2d Moneylenders and Pawnbrokers sec. 2; see also Morton v. City of Macon, 111 Ga 162, 36 S.E. 627 (1900);Louisville v. Pooley, 136 Ky 286, 124 S.W. 315(1910);Rodge v. Kelly, 88 Miss 209, 40 So 552 (1906). However, the cases supporting such a proposition are quite old, and there is a contrary opinion in the case law. See Wood v. Krepps, 168 Cal 382, 143 P. 691 (1914);Levinson v. Boas, 150 Cal 185, 88 P. 825 (1907). There appear to be no recent cases discussing a city's right to ban pawnshops as a matter of zoning or as a "nuisance." Some Minnesota - cities specifically list pawnshops as nuisances in their zoning ordinances. • (See attached Appendix) A fairly recent Minnesota Court of Appeals decision, however, may have some applicability to this unresolved issue. See Apple Valley Red-E-Mix v. City of St. Louis Park, 359 N.W.2d 313 (Minn. App. 1984)(absent a court determination that a business is a public nuisance or a nuisance per se, a city cannot legislate that business out of existence; court left open the issue of whether a city can generally eliminate a use within its boundaries without showing that the use is injurious to the public health, safety, or welfare). L. Buffer Zones. In addition to confining pawnshops to certain zoning districts, several cities erect buffer zones around pawnshops in order to prevent such uses from being close to certain "sensitive uses" such as schools, parks, licensed child • care centers, and libraries. Such buffer zones are common in the zoning 11