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In April 1984, the city of Indianapolis enacted an ordinance prohibiting the distribution of pornography.' The ordinance, following the theories of Catharine MacKinnon and Andrea Dworkin, went beyond addressing materials considered legally obscene. The ordinance targeted matter that combined sexually explicit images with depictions of women as enjoying pain, assault, humiliation or certain other forms of degradation. The ordinance had a rather short life. The Association of American Booksellers, the Association of American Publishers, a local video rental store, a resident of Indianapolis, and other plaintiffs challenged its constitutionality. In November 1984, the federal district court held it unconstitutional. 2 This position was affirmed by the United States Court of Appeals for the Seventh Circuit in August 1985 in a case titled American Booksellers Association v. Hudnut.3 The Supreme Court of the United States affirmed without issuing an opinion.4 While the ordinance may have been short-lived, the scholarly controversy it engendered has had a much longer life. There have been articles in a feminist-legal-theory vein supporting efforts similar to those in Indianapolis,5 and there has been work using a feminist perspective to argue against such ordinances.6 There has been scholarship employing First Amendment theory to criticize the MacKinnon-Dworkin approach.7 There

The United States and Canadian Responses to the Feminist Attack on Pornography: A Perspective from the History of Obscenity