In Miller, the Court tried to formulate a concrete standard that distinguished hardcore pornography from protected expression, but ambiguity of terms such as 'prurient' and 'patently offensive' have fueled a debate over the meaning and application of that test. The article explores these problems, using the Court's decision in Brockett v. Spokane Arcades, Inc. to highlight ambiguities and show how lower courts are taking contemporary standards into account in defining obscenity. The author examines Indianapolis' attempt to regulate pornography through legislation based on the premise that pornography violates the civil rights of women. Also analyzed are arguments that pornography promotes violence. The final section discusses Carlin Communications, Inc. v. FCC, in which the U.S. Court of Appeals for the Second Circuit ruled that the Federal Communications Commission's regulation of 'dial-a-porn' services violated the first amendment. The article concludes that regulation of obscenity might be better left to the public than to courts or legislatures. 134 footnotes.