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[*Page 234 continued]

II. THE LAW OF CHILD PORNOGRAPHY

[Introduction to part III]

In this Part, I will describe the birth and growth of child pornography law. As  will be evident, the course of the law's evolution closely tracks the cultural crisis charted in Part I. I do not present here an analysis of the legal implications of these doctrinal developments, nor do I discuss their legitimacy  or wisdom. (I consider these questions in a separate article.) [149]

Rather, I tell the story of the historical development of the law in order to illustrate its chronological correlation with the cultural story recounted above. I trace two different themes in this history: the expansion of the rationale for banning child pornography, and the widening definition of the term.  

One peculiar aspect of child pornography law is that the doctrinal category has evolved with the Supreme Court in a strangely passive pose:

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Rather than attempting to define child pornography itself, the Court's cases have simply upheld statutory definitions. This is in stark contrast to the law of obscenity, for example, where the Court struggled to create the precise constitutional definition of the category and thereby to set a clear boundary beyond which states could not go. [150]

Aside from declaring the requirement of a few standard protective features (such as the requisite scienter, [151] or the need for a statute to specifically define the prohibited material), [152] the Court's task in child pornography law has been primarily to accept legislative enactments and prosecutorial ambits, and then to justify them within the First Amendment.

With Congress and states pushing further and further for limits on child pornography, this lack of a clear boundary - indeed the suggestion of some Justices that they would entertain even broader definitions of child pornography than current ones [153] - has made the Court's work seem like an invitation to statutory expansion. As legislatures expand the scope of child pornography law, as prosecutors rush to vigorously enforce these laws to their limits, the response of the courts, to much of this, has been acceptance. There is a sense of boundlessness in child pornography law.

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