New York State, dwelling of the publisher, St. Martin's Press, criminalized the distribution of non-obscene "baby pornography" in 1977, but the publisher instantly went to court docket and acquired an injunction versus the State. However, beginning in 1977, some states began to criminalize the distribution of even non-obscene so-known as "little one pornography," or "photos of abuse," which arguably is not safeguarded by the First Amendment.