was based on the fact that the convicted murderer had NAMBLA materials and had been found to have visited the group's website. The ACLU said that the suit against NAMBLA highlighted censorship of unpopular speech about sexuality. According to Wendy Kaminer, a longtime ACLU executive, the case was based on "widespread biases about a supposed link between homosexuality and pedophilia"; in fact, studies have shown that children are more likely to be preyed upon by heterosexuals in their extended families. Proving the incitement is difficult given the First Amendment to the U.S. Constitution standards that govern words in any medium. At the time the Internet was much less popular, so the point rested on the court's viewing the Internet as such a different media as to warrant a different legal standard. Despite the lawsuit's claims, the NAMBLA website displayed no erotica, nor conspiracies to rape or incitements to violence. In Brandenburg v. Ohio, , the US Supreme Court held that government cannot punish inflammatory speech unless it is directed to inciting and likely to incite imminent lawless action. In September 2001, the court declined the defense's request for summary judgment, because Brandenburg "does not foreclose liability 'on any set of facts that might be shown'" as to incitement just by NAMBLA's publications, meetings and website. But the court dismissed the suit based on the specific legal issue that NAMBLA is organized as an association, not a corporation. The Curleys continued the suit as a wrongful death action against individual NAMBLA members and NAMBLA Steering Committee members. The Curleys dropped the lawsuit in 2008. They had only one witness prepared to testify that NAMBLA somehow incited one of the convicted criminals in the murder of their son, and the judge ruled the witness was not competent to testify. Robert Curley said, "That was the only link we were counting on ... When they ruled that out, that was the end of the line." Effects NAMBLA had been the subject of several law enforcement sting operations and raids. It had also been accused of links in several high-profile child abduction cases, such as the 1979 Etan Patz case in New York City. The initial suspect was known to be attracted to young boys, but was eventually determined not to be Patz's murderer. In February 2017, Pedro Hernandez, a clerk in a local bodega in 1979, was convicted of the kidnapping and murder