held that the CDA's "use of the undefined terms 'indecent' and 'patently offensive' will provoke uncertainty among speakers about how the two standards relate to each other and just what they mean." In 2000, Marvin Johnson, a legislative counsel for the ACLU, stated that proposed anti-spam legislation infringed on free speech by denying anonymity and by forcing spam to be labeled as such, "Standardized labeling is compelled speech." He also stated, "It's relatively simple to click and delete." The debate found the ACLU joining with the Direct Marketing Association and the Center for Democracy and Technology in 2000 in criticizing a bipartisan bill in the House of Representatives. As early as 1997, the ACLU had taken a strong position that nearly all spam legislation was improper, although it has supported "opt-out" requirements in some cases. The ACLU opposed the 2003 CAN-SPAM act suggesting that it could have a chilling effect on speech in cyberspace. It has been criticized for this position. In November 2000, 15 African-American residents of Hearne, Texas, were indicted on drug charges after being arrested in a series of "drug sweeps". The ACLU filed a class-action lawsuit, Kelly v. Paschall, on their behalf, alleging that the arrests were unlawful. The ACLU contended that 15 percent of Hearne's male African-American population aged 18 to 34 were arrested based only on the "uncorroborated word of a single unreliable confidential informant coerced by police to make cases". On May 11, 2005, the ACLU and Robertson County announced a confidential settlement of the lawsuit, an outcome which "both sides stated that they were satisfied with". The District Attorney dismissed the charges against the plaintiffs of the suit. The 2009 film American Violet depicts this case. In 2000, the ACLU's Massachusetts affiliate represented the North American Man Boy Love Association (NAMBLA), on first amendment grounds, in the Curley v. NAMBLA wrongful death civil suit. The organization was sued because a man who raped and murdered a child had visited the NAMBLA website. Also in 2000, the ACLU lost the Boy Scouts of America v. Dale case, which had asked the Supreme Court to require the Boy Scouts of America to drop their policy of prohibiting homosexuals from becoming Boy Scout leaders. 21st century Free speech In 2006, the ACLU of Washington State joined with a pro-gun rights organization, the Second Amendment Foundation, and prevailed in a lawsuit against the North Central Regional