changed social attitudes: one reason there are so few prosecutions for pornography is that juries will not convict. In Rosen v. United States (1896), the Supreme Court adopted the same obscenity standard as had been articulated in a famous British case, Regina v. Hicklin (1868). The Hicklin test defined material as obscene if it tended "to deprave or corrupt those whose minds are open to such immoral influences, and into whose hands a publication of this sort may fall". In the early twentieth century, literary works including An American Tragedy (Theodore Dreiser, 1925) and Lady Chatterley's Lover (D.H. Lawrence, 1928) were banned for obscenity. In the federal district court case United States v. One Book Called Ulysses (1933), Judge John M. Woolsey established a new standard to evaluate James Joyce's novel Ulysses (1922), stating that works must be considered in their entirety, rather than declared obscene on the basis of an individual part of the work. The Supreme Court ruled in Roth v. United States (1957) that the First Amendment did not protect obscenity. It also ruled that the Hicklin test was inappropriate; instead, the Roth test for obscenity was "whether to the average person, applying contemporary community standards, the dominant theme of the material, taken as a whole, appeals to the prurient interest". This definition proved hard to apply, however, and in the following decade, members of the Court often reviewed films individually in a court building screening room to determine if they should be considered obscene. Justice Potter Stewart, in Jacobellis v. Ohio (1964), famously said that, although he could not precisely define pornography, "I know it when I see it". The Roth test was expanded when the Court decided Miller v. California (1973). Under the Miller test, a work is obscene if: "Community" standards—not national standards—are applied to determine whether allegedly obscene material appeals to the prurient interest and is patently offensive. By contrast, the question whether a work lacks serious value depends upon "whether a reasonable person would find such value in the material, taken as a whole." Child pornography is not subject to the Miller test, as the Supreme Court decided in New York v. Ferber (1982) and Osborne v. Ohio (1990),Osborne v. Ohio, ruling that the government's interest in protecting children from abuse was paramount. Personal possession of obscene material in the home may not be prohibited by law. In Stanley v. Georgia (1969),