The Antipornography Civil Rights Ordinance defined pornography as the "graphic sexually explicit subordination of women, whether in pictures or in words". The ordinance was ruled unconstitutional by the Federal Appeals Court in "American Booksellers v. Hudnut" in Indianapolis (1985). Courts in California and New York have clearly rejected the argument that the making of pornography is prostitution. (See "California v. Freeman" (1988) and "People v. Paulino" (2005).) The Oregon Supreme Court went even further in "State v. Henry" (1987) by abolishing the legal definition of obscenity in that state, ruling it violated freedom of speech as defined in the state constitution.