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Justice Potter Stewart memorably captured the Court's challenge:"It is possible to read the Court's opinion in [past p*rnography cases] in a variety of ways.
In saying this, I imply no criticism of the Court, which, in those cases, was faced with the task of trying to define what may be indefinable.
Then criminal prosecutions could follow as, if, and when publishers defied the censor and sold their literature.
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What Chief Justice Warren Burger did, instead, was create a three-part test—now called the Miller test—that courts have used ever since to determine whether or not material qualifies as obscene.