The Court ruled unconstitutional a New York State law that required that an accused or convicted criminal's income from works describing the crime be deposited in an escrow account for 5 years for the benefit of victims and creditors. The case reveals much about the competing theories of free speech within the Rehnquist Court. However, the case is difficult to explain when considered with prior models of permissible government regulation of expression. If the concerns expressed in Blackmun's concurrence are taken seriously, it is possible that the Court has completely confused the once-clear notion of a marketplace of ideas in which any regulation is neutral with respect to the content of the ideas. Instead, the court should clarify and elucidate the issues. Footnotes