LOITER AT YOUR OWN PLEASURE:

Advertisement for Glendale Shopping Center, Indianapolis IN, 1958.

Gruen and Krummeck’s work was christened the Northland Center. It contained a post office, a doctor’s office, restaurants, public meeting rooms, community centers, and even a public library, in addition to the plethora of privately-owned local businesses and Hudson’s department store – Northland’s anchor. Northland was state-of-the-art. It was the first regional shopping center of its kind, and it was hailed as an advancement in urban planning, architecture, and public art. A New York art gallery traveled to Northland to document the art found in the common areas of Northland and put the art on exhibit back east.15 Gardens, fountains, and statues adorned the open-air walkways, terraces, and courts between the five individual buildings within the complex; these spaces were described by Gruen as the center’s most important “town-planning” element.16 The common spaces between the buildings were given names apropos of a town center; “Community Lane,” “Garden Terrace,” and “Great Lakes Court” conjured up a sense of belonging – a sense of society, to the tune of forty to fifty thousand visitors daily, on average.

The covered walkways between the buildings were art statements themselves. Some of the walkways had solid sidewalls, on which were mounted maps, advertisements, and announcements for community events. The exterior of these sidewalls was festooned with mosaics or acted as backdrops for statues in the Center’s gardens. Gruen surmised that the average visitor to a shopping mall cared “less about the facade [of the buildings] than about the character and atmosphere of the public spaces, where one might stroll or sit on benches.”17 Gruen actively understood the effect the aesthetics and social nature of the shopping center had on its clientele, and he recognized the important role that the suburban shopping mall played in the formation of social cliques and communities within the suburbs that they served.

Above: Merchandising plan for Northland Shopping Center, 1954.

Below: Layout of Northland c. 1991. The mall was enclosed in 1975 and shut its doors in 2015.18 Note the additional shopfronts built around the Hudson’s anchor and the constriction of the public space as a result.

The clientele that the suburban shopping mall catered to was predominantly young white mothers with small children, which presented the question of long-term engagement with the mall’s shops to mall developers. How do shopping malls advertise to busy homemakers who have to bring their young children along with them on their shopping trips? How could developers advertise the mall as an all-day experience for people with busy schedules? Simply put, the answer was to provide satisfaction in every aspect of these busy schedules in the same area: the shopping mall.

The Hillsdale Shopping Center in San Mateo, California, sought to answer these issues, and a 1957 promotional film, produced by the mall’s developers, lauded the mall as “a new concept in merchandising.” The film showcases the playgrounds one can drop their children off at while they shop, the variety of shops found within the center, the community room for the Women’s League housed in the mall’s JCPenney anchor store, and even the Farmer’s Market, a supermarket and eatery that contained twenty-two departments serving a wide variety of foods, housed next to a patio that one could only describe as a proto-food court. The film promotes an easy and quality dining experience on the Farmer’s Market’s patio after a day of shopping and gaiety at the mall.19

Yet another early advancement in the integration of the mall into the daily lives of suburbanites was its enclosure. In observing the weather conditions of Edina, Minnesota, a suburb of Minneapolis, which Gruen characterized as “buried in snow and bitter cold in winter, or scorching hot in summer, or rained out in spring and autumn,” he further revolutionized the suburban shopping experience by enclosing the roof, and by providing for a climate-controlled experience.20

Edina’s Southdale Center opened in October 1956, featuring a central indoor atrium dubbed the “Garden Court of Perpetual Spring,” as if to capitalize on the climate-controlled nature of the indoor mall. Skylights lined the roof of the common areas, and on a cold winter’s day, one might see snow piling up outside or on the roof, juxtaposed with perfectly in-season shrubs, trees, and flowers. TIME Magazine referred to Southdale as a “pleasure-dome with parking” and determined that the shopping mall was large and diverse enough that it could compete on its own terms with city retail districts.21 Southdale’s first ads promoted the climate-controlled environment, claiming “Every day will be a perfect shopping day.”22 Southdale’s developers leaned into the mall’s community-building potential, going so far as to posit its central influence in Edina by stating, “the development will offer a pleasant place to shop, a good spot in which to work, and a fine neighborhood in which to live.”23

The enclosure of Southdale Center certainly revolutionized the relevance of the shopping mall to suburbanites, at least in places of extreme weather, California’s Hillsdale Center was only enclosed in 1982, and many more continue to function as open-air malls today.24 By the early 1970s, the common thinking among developers was that enclosing shopping malls brought more business; Bergen Mall in Paramus, New Jersey, was enclosed in 1973, and general manager Louis De Ghetto surmised “there is no question that the enclosure will help us to remain competitive in a highly competitive market…an enclosed mall is where customers like to come.”25

Such a focus was placed on the common spaces of shopping malls by their developers that one must recognize the clear social impact the shopping mall had on its clientele, even if that effect was secondary to the economic factors involved in refurbishing the malls’ common space. In 1966, the grand opening of Harvey, Illinois’ Dixie Square Mall, later made famous as a filming location in the 1980 film The Blues Brothers, was advertised in the Chicago Tribune by drawing attention to its floor-to-ceiling water feature, dubbed the “Wonderfall,” and located at the central court of the enclosed mall.26 James Rouse, first with 1958’s Harundale Mall and its “Garden Court,” and later on in his work revitalizing urban centers as “festival marketplaces” (Philadelphia’s Faneuil Hall, Baltimore’s Harborplace, and Portland’s Pioneer Place, among others), emphasized the use of the public space in the mall as integral to fostering communities, dedicating his suburban and urban mall development to “better community and familial relationships and filling out the needs of residential suburban patterns.”27

Advertisement for Dixie Square Mall, Harvey IL, 1966

The 1968 Community Builder’s Handbook, produced by the Urban Land Institute, wrote that “a good shopping center can be so appealing that it brings customers repeatedly simply to browse and enjoy its beauty. It can make itself a public attraction, a focus of civic pride and interest.”28 Architectural critic-turned-mall historian Alexandra Lange agreed with that sentiment, concluding that what concerns the average mall-goer is not the stores themselves but “the shape of the corridor between the stores.”29

It is clearly evident that mallgoers began to understand the shopping mall as an element of public space given its close ties and engagement with suburban communities; it provided all the amenities, shopping opportunities, and recreational activities that one could find on a city’s Main Street. Shopping malls were venues for Red Cross blood drives, the settings for labor union pickets, the staging areas for local political campaigns, and the locus of activist protests and leafleting.30 The commons of the shopping mall was a breeding ground for community engagement, and it was so effective at doing so that public use of the mall began to challenge the private nature of the commercial enterprise at its core.

Historian Lizabeth Cohen placed this conflict within the context of a struggle between two of the freedoms that Americans hold most sacred: the right to free speech and the right to private property.31 Even if people perceive the shopping mall’s common areas as public space, isn’t the shopping mall itself still private property and, therefore, subject to the owner’s discretion? In fact, the Supreme Court precedent on this exact question was answered back in 1946 in the case of Marsh v. Alabama.

Grace Marsh was a resident of Chickasaw, Alabama. She was also a Jehovah’s Witness, which meant that part of her religious vocation instructed her to proselytize the masses. Except Chickasaw was a company town owned entirely by the Gulf Shipbuilding Corporation, and when Marsh began handing out religious literature in front of the Chickasaw post office, she was told that she needed a permit and arrested when she protested that a violation of the company’s rules could not apply to her as she was neither an employee of Gulf nor in Gulf’s work facilities. Marsh argued that her First and Fourteenth Amendment rights were violated, but she was still convicted in the Alabama court system. Marsh then appealed to the appellate courts in Alabama, for which the ruling was upheld, and then Marsh petitioned, unsuccessfully, for the Alabama Supreme Court to review the lower courts that had convicted her. Finally, Marsh appealed to the U.S. Supreme Court.

The Supreme Court’s decision, issued on January 7, 1946, overturned the Alabama courts in favor of Marsh. The court argued that Gulf’s company town had assumed the functions of a public space and, therefore, must bear those respective constitutional responsibilities.32 In the court’s own words, the state of Alabama:

[Cannot] impose criminal punishment on a person for distributing religious literature on the sidewalk of a company-owned town contrary to regulations of the town’s management, where the town and its shopping district are freely accessible to and freely used by the public in general.33

Furthermore, the Marsh decision ruled that the rights of the property owners themselves are regulated and restrained in cases where their property has been opened up to public use, very much the opposite of what was argued in favor of Gulf during the initial lower court case in Alabama:

Ownership does not always mean absolute dominion. The more an owner, for his advantage, opens up his property for use by the public in general, the more do his rights become circumscribed by the statutory and constitutional rights of those who use it.3

When the Supreme Court heard its first case regarding the constitutional rights of the general public in the quasi-public forum of the shopping mall – 1968’s Amalgamated Food Employees Union Local 590 v. Logan Valley Plaza, Inc,. the Court looked to the Marsh decision as its precedent. The union had attempted to picket a grocery store located in the Logan Valley Plaza in Altoona, Pennsylvania, and the state of Pennsylvania’s courts had enjoined the union for doing so on private property. None other than Shelley defender Thurgood Marshall issued the majority opinion, which touched upon the growing importance of the shopping mall and its ties to the suburban population of the United States.

The economic development of the United States in the last 20 years reinforces our opinion of the correctness of the approach taken in Marsh. The large-scale movement of this country’s population from the cities to the suburbs has been accompanied by the advent of the suburban shopping center.35

Echoing the decision in Marsh, Marshall wrote that “Logan Valley Plaza is the functional equivalent of a ‘business block’ and for First Amendment purposes must be treated in substantially the same manner.”36 Justice William Douglas concurred, arguing that “it is clear that respondents [Logan Valley Plaza] have opened the shopping center to public uses. They hold out the mall as ‘public’ for purposes of attracting customers and facilitating delivery of merchandise.” The court’s opinion in Logan Valley was split 6-3; and though the majority opinion staunchly upheld the notion of the shopping mall as a public venue and, therefore, subject to the responsibilities and liberties of a public space, four of the majority opinion’s Justices saw their decision overturned just four years later in 1972’s Lloyd Corp, Ltd. v. Tanner.

A group of anti-Vietnam War protestors, led by Donald Tanner, stood in the commons of Portland, Oregon’s Lloyd Center Mall, where they distributed leaflets and flyers inviting recipients to attend a meeting of the “Resistance Community.” Because of the precedent laid down just four years earlier in Logan Valley, the district court issued an injunction against Lloyd Center Mall when mall security removed the protestors from the premises.37 In a reversal of Logan Valley, the Supreme Court decided 5-4 in favor of Lloyd Center Mall’s right to remove the protestors. Justice Lewis Powell delivered the majority opinion that struck down Logan Valley’s precedent, in which he made clear a distinction between the Center itself and the newly coined “malls” between the stores. These malls, the Court decided, did not constitute public pathways but rather “private, interior promenades with ten-foot sidewalks serving the stores.”38 The majority opinion further stated that because the malls primarily served traffic to and from the stores located within the center and were not subject to the open-ended foot traffic of a public sidewalk, the pathways themselves could not be considered public space.

Despite this, the majority opinion also admits that the pathways within Lloyd Center Mall are not physically closed at certain hours when the stores along those same pathways are. It is considered by the court that this is done “as pedestrian window shopping is encouraged within reasonable hours” by the mall.39 Furthermore, Lloyd Center Mall had embedded discretionary signs into the floors at each entrance to the mall, stating that the mall’s pathways were not for public use. Affirming this, the Court rejected the Logan Valley reading of the Marsh decision, asserting that the Logan Valley reading was “expansive” and neither necessary nor appropriate.40

Justice Marshall revisited the Court’s majority opinion from four years earlier in the dissenting opinion issued by the four Justices who had upheld Logan Valley’s decision. The dissent contended that Lloyd Center Mall was even more of a public business district than Logan Valley Plaza because of its size, accessibility from public roads, and variety of stores and services contained within the mall. Furthermore, the content of speech being questioned in Lloyd Corp. v. Tanner was political and much broader than that of the union’s picketing at Logan Valley Plaza; and so, Marshall and his fellow dissenters argued, the protesting should be allowed to reach a wider audience, and should be accepted at the mall, where it was even more likely to elicit a positive response from mallgoers than in the Logan Valley case, essentially maintaining the idea that the broader the speech is, the freer it should be.41

From the time of Lloyd Corp v. Tanner, now fifty years in the past, the question of free speech in the shopping mall, and in fact, the question of whether the shopping mall even constitutes public space, has been decided on a case-by-case (or in some cases, a state-by-state) basis. The 1980 Pruneyard v. Robins decision, the currently-standing precedent on free speech in shopping malls, concurred with the decision in Lloyd Corp. v. Tanner insofar as the rights of private property not being infringed upon by the federal government. The majority opinion wrote:

The reasoning in Lloyd Corp. v. Tanner – which held that the first Amendment does not prevent a private shopping center owner from prohibiting the distribution of handbills unrelated to the center’s operations – does not ex proprio vigore [of its own force] limit a State’s authority to exercise its police power or its sovereign right to adopt in its own constitution individual liberties more expansive than those conferred by the Federal Constitution.

Though Justice Powell and Justice Marshall, in their distinct and opposing opinions on Lloyd Corp. v. Tanner, both insisted that the Logan Valley ruling had not been overturned in Lloyd, its effect had certainly been enough of an influence on Pruneyard that the 1980 case ended up solidly declaring Logan Valley overturned.42

Pruneyard concerned the freedom of high school students to petition in the commons of Pruneyard Shopping Center in Campbell, California. Initially, the Santa Clara County Superior Court ruled against the students, citing Lloyd Corp. v. Tanner, but the ruling was reversed by the California Supreme Court, which held that the Pruneyard Shopping Center was sufficiently dedicated to public use that First Amendment rights must be upheld in the mall, and additionally pointed to earlier cases in which California had enshrined such rights into the state constitution.43 The U.S. Supreme Court upheld the California Supreme Court’s reversal of the initial superior court decision, and thus, the overturning of Logan Valley was complete.

The California Supreme Court’s lasting precedent on the shopping mall as public space is further emphasized in their 2012 decision in Ralphs Grocery Co. v. United Food and Commercial Workers Union Local 8. The decision was integral to the view of the mall and its public space in California because it offered California’s first true definition of what comprises public space in a shopping mall:

We agree with these intermediate appellate decisions that to be a public forum under our state Constitution‘s liberty-of-speech provision, an area within a shopping center must be designed and furnished in a way that induces shoppers to congregate for purposes of entertainment, relaxation, or conversation, and not merely to walk to or from a parking area, or to walk from one store to another, or to view a store‘s merchandise and advertising displays.44

While the state law primarily concerned questions of accessibility and broad usage, malls were actively encouraging both to shoppers during their hours of operation, though the Supreme Court decision in Lloyd ruled that the Oregon shopping center did not. The opinions issued in Logan Valley and Lloyd describe the mall in terms of either public or private space, but neither do so in a way that would substantially comply with the definition California used forty years later, which indicates a lack of consensus on a legal view of the shopping mall’s public space in the fifty-four years since Logan Valley.

Paul William Davies, in his extensive analysis of the Pruneyard decision and its far-reaching implications, refers to the period 1972-1980, the time between the Lloyd and Pruneyard decisions, as wholly supporting restrictive access to shopping malls. Davies reflects that though federal and state laws were lax or nonexistent in many places concerning enforced public access to shopping malls, malls still provided that broad public access to their common spaces.45

Furthermore, the implications of public space in shopping malls synthesized other questions about the services offered in shopping malls and if they, too, would be subject to public scrutiny and benefits. Discussing the outcome of the Pruneyard decision five years after, Pruneyard public relations manager Carmen Rutlen posed a question to William Kowinski: if the mall was treated as public space, should the public be footing the bill for the mall’s security outfit, or for the maintenance of the mall?46 The Logan Valley decision had concluded that shopping malls were, in fact, public space and, therefore, subject to laws concerning public space, but the 1968 decision never spoke a word as to whether the public, through taxes, owed anything back to the shopping mall, as it does with any other, unambiguous public space. The new precedent, first put forth in Lloyd Corp. v. Tanner, cemented by the Pruneyard decision, likewise made no mention of the services contained in the mall and whether they constituted a public service or a private entity, which further left the question in uncertain terms.

The notion of the shopping mall’s public space is thrown further into doubt when looking from a racial perspective. The redlining and discriminatory housing policies that caused a homogenous, White population to emerge in the suburbs certainly skewed the clientele of the first shopping malls in a majority-White direction, but suburban shopping malls were still functionally segregated in post-civil rights America.

In the case of Washington, D.C., and its outlying suburbs, Tyson Corners Center was the first suburban shopping mall built in the area. Though Washington is a majority-Black city, Tyson Corners was built for White communities; it was located southwest of Washington, in the affluent and then-conservative bastion of Fairfax County, Virginia. In the fifteen years between its 1968 opening to Kowinski’s 1983 visit, Tyson Corners’ clientele had remained largely unchanged: White and aging. The population of the mall, in some cases, even implied to Kowinski and his fellow mall sociologists what was truly on the minds of Tyson Corners mallgoers: “We come here because it has everything we want and nothing we don’t want. There aren’t any problems with parking, or crowds, or crime, or…well, we don’t have to say what the other problems are.”47

Four years after Tyson Corners first opened its doors, the Landover Mall was opened in Prince George’s County, Maryland – just on the northeastern edge of Washington. Population projections from the 1970 census appeared to show an exodus of a wealthy, White middle-class moving into Prince George’s County; the Landover Mall was an attempt to capitalize on newly built suburbs in the area and their affluent new residents.48

However, the Landover Mall did not end up catering to a wealthy, White, suburbanite population, as Prince George’s County did not grow as the 1970 census had predicted; far fewer people moved to the county during the 1970s, and the incoming population was predominantly Black. Landover Mall became a mall surrounded by low-income housing and apartment blocks as developers in Prince George’s County scrambled to retool their suburban plans in order to recoup losses on their land speculations. Landover Mall’s clientele grew from 35% Black in 1972 to 70% Black by 1980, and the retailers in Landover Mall began to retool their merchandise as well.

Once the retailers in Landover Mall accepted the concept of a largely Black clientele, the mall itself went through a period of rebirth. Formerly broken fountains and dying plants were fixed and replaced, the commons of the mall were cleaned and restored, and ad campaigns for the mall began to cater to a Black audience.49

But the adjustment period carried much tension between store managers and mallgoers; managers decried the rising number of “street kids” loitering at the mall and driving away “other” customers. In 1978, the mall’s merchants petitioned the Washington Metropolitan Area Transit Authority to remove a bus stop near the mall’s entrance, complaining that the bus brought large numbers of “youths” to the mall; Kalman Brooks – the owner of two shoe stores in the Landover Mall and one of the rising number of Black retailers at the mall, pointed to a double standard: “Young kids cause ‘mischief’ at White Flint [a White mall in the area]. Here, they were ‘trouble-makers’ and ‘hoodlums.’”50 Regardless, Landover Mall made history as the first successful Black suburban mall in the nation.

The racial factors involved in and resulting from “White flight” to the suburbs similarly affected the way downtowns and urban centers accepted and even adopted some of the public aspects of the shopping mall. Many cities, especially around their urban cores, downtowns, and commercial districts, became predominantly populated by people of color as the White population left for the suburbs.

Urban planning, according to New York congresswoman and inner-city native Shirley Chisholm, was undercutting infrastructure in Black areas in attempts to attract White populations back to the cities in revitalization efforts. Chisholm insisted: “Black people have no intention of being left to die in burned-out cities…but unless the [revitalization] process involves more than bringing in money and high-paid, white-collar workers back to the city, we will be experiencing negative social behavior.”51 Chisholm understood that city centers had suffered major economic losses as stores either closed due to revenue loss or moved to the suburban shopping malls for a more reliable market, but pleaded with her audience, the American Society of Planning Officials, that in order to revitalize downtowns, you had to invest in the people already living there.

Shopping malls did begin moving into city centers and downtowns in various ways. Shortly after the early shopping mall boom in the late 1950s, cities started looking at shopping malls from the perspective of rebuilding a downtown to encourage foot traffic, recreation, and pleasurable shopping experiences, indicating that the suburban shopping mall introduced a winning formula in commercial- and public-space design. Cities began to divert traffic from certain streets in their downtown areas and built the first pedestrian malls. Victor Gruen looked to the downtown of Fresno, California as the setting for his own successful experiment in revitalizing a downtown as a walkable space akin to his shopping mall design.52

Other mall architects like Rouse took the idea of the pedestrian mall and further developed it into the concept of “festival marketplaces,” an urban plan for shopping malls that more succinctly melded the ideas of the city square and shopping mall together.53 The festival marketplace’s success, realized by Rouse in Faneuil Hall, Harborplace, and Pioneer Place, galvanized the notion that a shopping mall’s success was tied to its ability to engage a community by providing more than just retail services.

In 1983, Hugh Kinniburgh, an NYU Film student, inadvertently corroborated what Rouse and other mall developers concluded from the success of his festival marketplaces. Kinniburgh set out to his local suburban shopping mall, Roosevelt Field Mall in Garden City, to interview mallgoers with one simple question: “Why do you come to the mall?” The resulting documentary, Mall City, portrays Kinniburgh interacting with a diverse crowd during a day at the mall.54

Roosevelt Field was built in 1956, mainly to serve the New York City suburbs cropping up on Long Island. But in the succeeding three decades, the mall’s population was no longer homogenous, nor did the mall’s clientele now come exclusively from the suburbs. Kinniburgh showcases the diversity of the clientele: young, old, White, Black, Hispanic, suburbanite, urbanite, and even the homeless. What Kinniburgh discovered contradicted what the merchants of Landover Mall feared in the 1970s: regardless of race or age, most mallgoers came to hang out with their friends, not to cause trouble. A 70-year-old interviewee, when asked by Kinniburgh where he hung out as a teenager, replied that people his age “mostly hung out on street corners…we had no place to hang out – this [mall] is fantastic.”55

Mall patrons from the city also celebrated the advent of the shopping mall as a destination, reflecting that the change in scenery between Brooklyn or Queens and Long Island was nice and relaxing and that if you lived in the city, “You wanna get away. So what do you do? You go to Long Island.”56 Roosevelt Field Mall encouraged a diverse population of urbanites to venture out to Garden City to shop at the mall, as buses routinely ran between the ethnically diverse Jamaica neighborhood of Queens and the mall itself.57

But the Roosevelt Field Mall – where Kinniburgh’s interviews were set against the backdrops of food courts and neon signs, in front of mall arcades and movie theaters, and buyers explaining their chain-store purchases – paints a very different picture of what the shopping mall was to its clientele compared to the shopping malls of the 1950s. This later phase of the shopping mall is much more familiar to the modern mall-goer. Where private enterprises within the mall were expanded or added, the public space in the mall was constricted or altogether repurposed.

The encroachment on public space in the shopping mall by commercial establishments coincides with an effort by mall developers to revitalize the shopping mall, perhaps best expressed in the 1970s by mall architect Jon Jerde’s conviction that malls needed to become more entertaining in order to draw people in from wider areas and in order to build “communality” at the shopping mall.58 The Jerdean model of the shopping mall formulated a concept that relied both on greater commercialism and greater community-building, which sounds, at least at first, quite contradictory.

Commercial encroachment on the mall’s public space did not begin with malicious intent toward the public space, however. James Rouse’s 1971 attempt at building a food court at the Plymouth Meeting Mall in the Philadelphia suburbs aimed at creating the appearance of a “community picnic.”59 Plymouth Meeting Mall’s food court looked much like a modern food court: small, individually owned counters arranged to face a sizable, common, seating area. Yet the Plymouth Meeting Mall food court struggled, as patrons found the space to be too small and the offerings too lacking or inconsistent.

Rouse’s second attempt at a food court added a dedicated second floor to the Paramus Park Mall in New Jersey; upon the mall’s March 1974 opening, the food court was instantly a hit.60 Other developers followed suit, and developers were so eager to profit off the latest in shopping mall innovation that they began adding food courts wherever they had the space. Oftentimes, the “available” space repurposed for food courts constituted the aesthetic, walkable courts and avenues between shopfronts.61

Rouse further contributed to this change in mall focus and composition nearly by accident. Approaching opening day for Boston’s Faneuil Hall, tenant occupancy appeared to be dangerously low, and in Rouse’s desperate attempt to fill space in the marketplace on short notice, he devised a plan for temporary tenancy that soon became commonplace in the shopping mall: the kiosk.62

By renting the “empty space” used mainly for pedestrian traffic, mall owners could increase their revenue and place more businesses inside their mall without spending time and money developing the mall for further retail space.63 National chain stores appeared in shopping malls across the nation as consumers began frequenting larger franchises that could undercut local businesses on the prices of anything and everything.64 The mall was losing relevance to the communities it originally intended to serve.

However, in the Jerdean plan for the shopping mall, entertainment is a clear focus, and in order for community engagement to occur, a mall does not need to draw an audience; it simply creates its own. With the emergence of arcades and cinemas at the shopping mall, communities flocked to these entertainment complexes whether they already existed or not. Communities formed at these establishments within the mall, independent of outside influences, because they were a common denominator among people. In short, mall culture was created. Most notably, the Jerdean phase of mall development encouraged the emergence and growth of adolescent culture at the shopping mall.

The shopping malls of the 1980s, following the Jerdean “entertainment complex” plan, advertised themselves as something more than retail space and something entirely different altogether than the relaxing, open, and friendly atmosphere of Gruen’s initial design. Malls advertised themselves as wondrous destinations for mallgoers. Television ads in the early 1980s shifted from portraying malls as strictly retail spaces towards proclaiming them as “an exciting place to go” or that “this is where the good times hide” in order to draw people into the enigmatic glamor of the shopping mall.65

Malls began leaning heavily into the ethereal, futurist mystique of shopping, leisure, pleasure, and anything else one could ever want – all under one roof. Century III Mall outside Pittsburgh, Pennsylvania opened in 1979 and was named in honor of the third century of American history it advertised itself as “ushering in.”66 On the occasion of the March 1980 completion of Century III’s Phase II development – which added 46 new stores (three of them anchors), sculptures, and a three-story food court—an advertisement ran in the Pittsburgh newspapers emphasizing Century III as “a complete sensation.”67

“It’s A Complete Sensation” advertisement for Century III Mall, West Mifflin, PA, 1980.

Embracing the new entertainment services found within the mall, teenagers began community-building within the arcades, food courts, and cinemas at which they gathered, but that did not preclude the importance of the common avenues of the shopping mall as the premier meeting spot for teens across America.

George Lewis’ 1990 study on community-building at shopping malls concluded that teens congregated at the mall to meet other teenagers. Lewis asserts that teenagers hang out at the mall because their parents view the shopping mall as a safe-enough environment and because it is “one of the few places teenagers can go in this society where they are–albeit reluctantly–allowed to stay without being asked to leave.”68 He gained insight into mall management’s view on adolescent loitering at his case study shopping malls, as security guards explained to him that they “knew they gotta hang out somewhere.” Mall security only removed teenagers from these malls in situations where teenagers were creating disturbances or disrespecting mall management.69 This view of the mall’s communities once again points to a post-Lloyd legal view of the mall’s public space, where personal freedoms and private property rights overlap in a confusing way: personal rights to inhabit and make use of the shopping mall’s common areas are decided on a case-by-case (and state-by-state) basis. It also attributes a characteristic of communality to the shopping mall that is present only in practice. There is essentially a universal consensus among mall management on a singular rule for mall-goer behavior, which is emblazoned in a simple two-word phrase at every entrance to a shopping mall across the United States: “no loitering.”

The history of shopping malls tells us there is precedence for the inclusion of that rule; it was applied in both racial and economical manners to groups seen as undesirable to the image of the shopping mall, such as black mallgoers at Tyson Corners and Landover Mall in the greater Washington, D.C. area, as well as towards the “mall people” feared in downtown malls, which consisted largely of homeless populations that retailers, management, and mallgoers alike referred to as “an obvious menace to the business community.”70

Yet Lewis’ observations and interviews tell us that “no loitering” is just as flexible in definition as the concept of public space in the shopping mall itself. The concept of loitering itself is integral to the shopping mall and its success; Gruen’s model of the shopping mall encouraged communities to spend entire days at the mall, enjoying the common areas in addition to the retail elements of the shopping center. While mall management and retailers wished to keep up appearances for financial purposes, it was far less likely, by the time teen culture emerged at the shopping mall, that anybody retailers might consider potential customers would be turned away from the shopping mall simply for loitering.