The famous Indianapolis definition of pornography by Dworkin and MacKinnon paralleled their Minneapolis ordinance. The first was rejected by the United States Court of Appeals for the Seventh Circuit for several reasons. The ordinance did not use any of the accepted terms that the Supreme Court had developed over time for determining when material is obscene, including "prurient interest", "offensiveness", or "local community standards". Another concern was the way the women were depicted in the work. If women were referred to in the approved fashion stressing equality, the activity involved would be regardless of how sexually explicit it was. The Court also indicated that if women were referred to in a disapproving way depicting them as subversive or as enjoying humiliation, the activity would be unlawful regardless of the "literary, artistic or political qualities of the work taken as a whole". Judge Frank Easterbrook said: "We accept the premises of this legislation. Depictions of subordination tend to perpetuate subordination. The subordinate status of women in turn leads to affront and lower pay at work, insult and injury at home, battery and rape on the streets... Yet this simply demonstrates the power of pornography as speech." "Conceptions of Democracy in American Constitutional Argument: The Case of Pornography Regulation" by Frank Michelman, issued by Tennessee Law Review (vol. 56, no. 291, 1989) partially consented that "pornography is political expression in that it promulgates a certain view of women's natures and thus of women's appropriate relations and treatment in society", but also concluded that the Indianopolis ordinance was precisely designed to suppress that particular view by censoring pornography. Minneapolis ordinance was struck down on the grounds that it was ambiguous and vague, however, despite of its failure the proposal influenced other communities across the United States.