<P> There is also a fifth category of analysis . It is possible that some completely false statements could be entirely free from punishment . The Supreme Court held in the landmark case New York Times v. Sullivan (1964) that lies about the government may be protected completely . However, this category is not entirely clear, as the question of whether false historical or medical claims are protected is still disputed . </P> <P> Under the Miller test (which takes its name from Miller v. California), speech is unprotected if (1) "the average person, applying contemporary community standards, would find that the (subject or work in question), taken as a whole, appeals to the prurient interest" and (2) "depicts or describes, in a patently offensive way, contemporary community standards, sexual conduct defined by the applicable state law" and (3) "the work, taken as a whole, lacks serious literary, artistic, political, or scientific value". Some subsidiary components of this rule may permit private possession of obscene materials at one's home . Additionally, the phrase "appeals to the prurient interest" is limited to appeals to a "shameful or morbid interest in sex". </P> <P> The Court has also held that a person may only be punished if he knows the actual "contents of the material". In Smith v. California (1959), the Supreme Court thus gave a defense of "reasonable ignorance" to an obscenity charge . The basis for this exception is that justices have believed that obscenity has a "tendency to exert a corrupting and debasing impact leading to antisocial behavior". </P> <P> The exception for child pornography is distinct from the obscenity exception in a few ways . Firstly, the rule is much more specific to what falls under the exception . Secondly, it is irrelevant whether any part of the speech meets the Miller test; if it is classified under the child pornography exception at all, it becomes unprotected . The rule provides that speech is unprotected if it (1) "visually depicts" children below the age of majority (2) "performing sexual acts or lewdly exhibiting their genitals". Unlike the rules for simple obscenity, private possession of child pornography "may be outlawed". </P>

According to the supreme court when can free speech be limited cite cases