acting performance. The State did not appeal to the United States Supreme Court making the decision binding in California, where most pornographic films are made today. Origin of term The term "pornography" first appeared in an 1857 British medical dictionary, which defined it as "a description of prostitutes or of prostitution, as a matter of public hygiene", therefore pornography by itself was not a widely used term in nineteenth-century America and the term did not appear in any version of American Dictionary of the English Language in its early editions. The dictionary introduced the entry in 1864, defining it primarily as a "treatment of, or a treatise on, the subject of prostitutes or prostitution". Early charges used the term "obscenity" as well as after Miller v. California, though the term "pornography" remained as a reference entry: The censorship of pornographic materials in the United States was enabled by the way courts interpreted the First, and partially Ninth and Fourteenth amendments to the U.S. Constitution. The legal justification also includes the so-called harm principle, as in Canada and the United Kingdom. The absolutist interpretation of the First Amendment as applied to pornography has never been sustained by the Supreme Court. In the Investigation of Literature Allegedly Containing Objectionable Material, issued by the U.S. Congress Select Committee on Current Pornographic Materials in 1953, it was noted that "perhaps the greatest impediments to the prompt and effective enforcement of existing laws intended to control pornographic materials are the difficulties of establishing a precise interpretation of the word". During the Warren Court (1953–1969), the first notable court to face the cases of such kind, justices Potter Stewart, Byron White, and Arthur Goldberg shared the opinion that only hardcore pornography was not protected by the First and Fourteenth Amendments. This position was contested notably by U.S. Solicitor General James Lee Rankin (in office 1956–1961), but in Jacobellis v. Ohio Stewart concluded that criminal obscenity laws are constitutionally limited under the First and Fourteenth Amendments to hardcore pornography. Concurring in the 1957 Roth v. United States Justice John Marshall Harlan II wrote that "even assuming that pornography cannot be deemed ever to cause, in an immediate sense, criminal sexual conduct, other interests within the proper cognizance of the States may be protected by the prohibition placed on such materials." The 1967 Public Law 90-100 found the traffic in pornography to be "a matter of national concern",