The upcoming censorship of pornographic materials in the United States became based on the First, and partially Ninth and Fourteenth amendments to the U.S. Constitution. It also includes the so-called harm principle, as well as in Canada and the United Kingdom. The absolutist interpretation of the First Amendment as applied to pornography has never been sustained by the Supreme Court. In the "Investigation of Literature Allegedly Containing Objectionable Material", issued by the U.S. Congress Select Committee on Current Pornographic Materials in 1953, it was noted that "perhaps the greatest impediments to the prompt and effective enforcement of existing laws intended to control pornographic materials are the difficulties of establishing a precise interpretation of the word". During the Warren Court (1953–1969), the first notable court to face the cases of such kind, justices Potter Stewart, Byron White, and Arthur Goldberg shared the opinion that only hardcore pornography was not protected by the First and Fourteenth Amendments. This position was contested notably by U.S. Solicitor General James Lee Rankin (in office 1956–1961), but in Jacobellis v. Ohio Stewart concluded that criminal obscenity laws are constitutionally limited under the First and Fourteenth Amendments to hardcore pornography. Concurring in the 1957 "Roth v. United States" Justice John Marshall Harlan II wrote that "even assuming that pornography cannot be deemed ever to cause, in an immediate sense, criminal sexual conduct, other interests within the proper cognizance of the States may be protected by the prohibition placed on such materials."