d The transportation of pornography in interstate commerce was banned in the 1973 case of "United States v. Orito". The Supreme Court upheld zoning restrictions that either quarantine or disperse pornography merchants, leaving it to local officials to determine whether local interests are best served by restricting all porn merchants to a single district. Though the Court has also upheld zoning that prohibits pornographic entertainment within a certain distance of a school, the legitimate primary purpose excludes the preventing of access by minors which can be achieved much more directly by simple restrictions. On May 13, 2002, writing for the majority in "Ashcroft v. American Civil Liberties Union", Justice Clarence Thomas stated that using community standards to identify material that could be harmful to minors does not make the law overly broad and therefore unconstitutional under the First Amendment.