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Advocates for the ordinance argued that it would promote civil rights by combating sex discrimination. But rivals argued that the ordinance was in conflict with the First Amendment. A federal court ruled against the ordinance. The case was Miller v. California. In Miller, the court defined a basic legal common for pornography. According to the Miller choice, pornography must meet three necessities to be categorized as obscene. Pornography must portray sexual conduct defined by law, it must lack serious creative or literary value, and it must entice a prurient attention. This court choice lead the way for a legislative attack on pornography. Two women, Catharine A. MacKinnon and Katherine Dworkin, attempted a legislative solution in 1983.

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