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Words and pictures may serve an almost limitless variety of purposes. They may be the instruments with which a political pamphleteer urges a change in government policy, but they may also enable the child pornographer to display for the sexual pleasure of paying customers photographs of children engaged in sexual activity. The former is unquestionably at the core of the First Amendment's protection of freedom of speech and press.' The latter is equally clearly some distance from that core.2 In New York v. Ferber3 the Supreme Court held child pornography to be so far from the core as to be unprotected by the First Amendment. Ferber

Codifying the First Amendment: New York v. Ferber