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Advocates for the ordinance argued that it would advertise civil rights by fighting sex discrimination. But rivals argued that the ordinance was in battle with the First Amendment. A federal court ruled in opposition t the ordinance. The case was Miller v. California. In Miller, the court outlined a basic legal typical for pornography. According to the Miller determination, pornography must meet three requirements to be classified as obscene. Pornography must portray sexual behavior defined by law, it must lack severe creative or literary value, and it must entice a prurient attention. This court resolution cleared the path for a legislative attack on pornography. Two women, Catharine A. MacKinnon and Katherine Dworkin, attempted a legislative answer in 1983.

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