Adoption of obscenity laws in the United States was largely due to the efforts of Anthony Comstock. Comstock's intense lobbying led to the passage in 1873 of an anti-obscenity statute known as the Comstock Act. Comstock was appointed postal inspector to enforce the new law. Twenty-four states passed similar prohibitions on materials distributed within the states. The law criminalized not only sexually explicit material, but also material dealing with birth control and abortion. Although lower courts in the U.S. had used the Hicklin standard sporadically since 1868, it was not until 1879, when prominent federal judge Samuel Blatchford upheld the obscenity conviction of D. M. Bennett using "Hicklin", that the constitutionality of the Comstock Law became firmly established. In 1896, the Supreme Court in "Rosen v. United States", , adopted the Hicklin test as the appropriate test of obscenity.