 In 1983, two of the most prominent anti-pornography feminists in the United States, Catharine MacKinnon and Andrea Dworkin, drafted an anti-pornography ordinance at the behest of the Minneapolis Council. A similar ordinance was passed by the Indianapolis City Council in 1984, but later overturned on appeal by the U.S. Supreme Court on the grounds that the ordinance violated pornographers’ First Amendment right to freedom of speech. Importantly, the ordinance did not seek to impose criminal prohibitions or sanctions on pornography: It did not seek to make the production, sale or consumption of pornography a criminal offence, punishable by imprisonment (as, for example, producing, selling or consuming heroin is a criminal offence). MacKinnon and Dworkin thought that criminalizing the production, publication or consumption of pornography would be counterproductive, serving to drive the industry underground, thereby only further obscuring the harm it causes to women. Rather, the ordinance sought civil remedies that would enable women who are harmed in the making of pornography, or as a result of its consumption, to sue for a future ban on sexually explicit material demonstrated to be harmful and to collect damages from pornographers for provable harm done by that material. There is some argument about whether the proposed legislation would have amounted to censorship, strictly speaking, since it did not seek to place a prior ban on the publication of pornographic materials. But insofar as the legislation allowed for courts to award and enforce injunctions against publication of material demonstrated to be harmful, many think that the legislation may have been functionally equivalent to censorship in practice (assuming that courts would in fact have been willing to award and enforce injunctions).