In the United States, the first federal law to ban the for-profit production and distribution of child pornography was the Protection of Children Against Sexual Exploitation Act of 1977. In response to New York v. Ferber, 458 U.S. 747 (1982), a U.S. Supreme Court decision allowing the prohibition of child pornography even if it did not meet the obscenity standard established in Miller v. California, Congress passed the Child Protection Act of 1984, broadening the definition of child pornography and criminalizing nonprofit child pornography trafficking. The 1986 Meese Report found that child pornography was a cause of serious harm; this led to the passage of the Child Sexual Abuse and Pornography Act of 1986, which increased penalties for repeat offenders.[78]