s protection to written fiction, although the legal presumption that it does not protect obscene literature has never been overcome. (Instead, pornography has successfully been defined legally as non-obscene, or "obscene" been shown to be so vague a term as to be unenforceable.) In 1998 Brian Dalton was charged with creation and possession of child pornography under an Ohio obscenity law. The stories were works of fiction concerning sexually abusing children which he wrote and kept, unpublished, in his private journal. He accepted a plea bargain, pleaded guilty and was convicted.[110] Five years later, the conviction was vacated.Importing books and texts across national borders can sometimes be subject to more stringent laws than in the nations concerned. Customs officers are often permitted to seize even merely 'indecent' works that would be perfectly legal to sell and possess once one is inside the nations concerned. Canada has been particularly notorious for such border seizures.[ත