charged under the PROTECT Act for the lone act of possessing art deemed obscene, in the form of seven manga graphic novels ordered from Japan. In the case United States v. Handley, district court Judge James E. Gritzner ruled that two parts of the PROTECT Act that criminalized certain depictions without having to go through the Miller test were overbroad and thus unconstitutional. Handley still faces an obscenity charge. Both prosecutors and defense attorneys noted that the plea deal was due to the high risk of a constitutional challenge, and the federal government agreed that Handley would not be required to register as a sex offender. A later ruling in United States v. Dean challenged the Handley overbreadth ruling because the Handley ruling did not prove that the sections had "substantial overbreadth". Criticism According to Adler, Delohery, and Charles Brownstein, "the current law raises concerns for creators, publishers, and collectors of various forms of entertainment (including, but not limited to, comics/manga, video games, and fine art)." Bell argues that the PROTECT Act should be reexamined by Congress because it infringes on the First Amendment's right to free expression. See also Laws regarding child pornography Legal status of drawn pornography depicting minors References https://www.rcfp.org/journals/the-news-media-and-the-law-winter-2000/acts-prohibition-simulated/ Further reading (Archive) Fraley, Amy. "Child Sex Tourism Legislation Under the PROTECT Act: Does It Really Protect?" (Archive). St. John's Law Review. Spring 2005, Issue 2, Volume 79, Number 2, Article 7. Posted in February 2012. p. 445-484. External links Text of the Act at GovTrack Text of the Act at THOMAS Text of 11th Circuit decision in United States v. Williams Legislative history at GovTrack Child pornography law Sex laws United States federal criminal legislation Acts of the 108th United States Congress