had developed over time for determining when material is obscene, including "prurient interest", "offensiveness", or "local community standards". Another concern was the way the women were depicted in the work. If women were referred to in the approved fashion stressing equality, the activity involved would be regardless of how sexually explicit it was. The Court also indicated that if women were referred to in a disapproving way depicting them as subversive or as enjoying humiliation, the activity would be unlawful regardless of the "literary, artistic or political qualities of the work taken as a whole". Judge Frank Easterbrook said: "We accept the premises of this legislation. Depictions of subordination tend to perpetuate subordination. The subordinate status of women in turn leads to affront and lower pay at work, insult and injury at home, battery and rape on the streets.... Yet this simply demonstrates the power of pornography as speech." Conceptions of Democracy in American Constitutional Argument: The Case of Pornography Regulation by Frank Michelman, issued by Tennessee Law Review (vol. 56, no. 291, 1989) partially consented that "pornography is political expression in that it promulgates a certain view of women's natures and thus of women's appropriate relations and treatment in society", but also concluded that the Indianopolis ordinance was precisely designed to suppress that particular view by censoring pornography. Minneapolis ordinance was struck down on the grounds that it was ambiguous and vague, however, despite of its failure the proposal influenced other communities across the United States. In May 2005 U.S. Attorney General Alberto Gonzales established an Obscenity Prosecution Task Force. The task force, according to a Department of Justice news release on May 5, was "dedicated to the investigation and prosecution of the distributors of hard-core pornography that meets the test for obscenity, as defined by the United States Supreme Court." Under President Bush's and Gonzales' rationales the FBI Adult Obscenity Squad was recruited in August 2005 to gather evidence against "manufacturers and purveyors" of adult pornography. Child pornography The 1970 Lockhart Commission recommended eliminating all criminal penalties for pornography except for pornographic depictions of minors, or sale of pornography to minors. However, prior to 1977, only two states had laws which prohibited the use of children in the production or distribution of pornographic materials or performances. In 1977, the Department of Justice strongly endorsed legislation which banned the production and dissemination of child pornography. These efforts have been