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How werewolf erotica found its way to prison

Much amusement greeted the announcement, earlier this month, that the 1st District Court of Appeal in San Francisco had overturned previous rulings to allow an inmate of a state prison to receive a book. The book, "The Silver Crown" by Mathilde Madden, had been confiscated by prison authorities. The case raises serious issues about the control prison administrators have over the reading material inmates may access, but the sniggering was over the book itself, a work of "werewolf erotica."

The ruling conflicts with an earlier finding by a court in the 5th District concerning the amount of leeway corrections officers may exercise in confiscating material. "Prison authorities had a legitimate penological interest in prohibiting inmates from possessing sexually explicit materials," Justice James Richman wrote, but in the case of "The Silver Crown" and the prisoner who wants to read it, they overstepped their powers and engaged in an "arbitrary and capricious application of the regulation." Richman declared that "The Silver Crown" does not meet the famous "three-pronged" standard by which American courts have determined obscenity since the Supreme Court of the United States' decision on Miller v. California in 1973. Specifically, he found that Madden's novel (the second installment in a series) is not a work that, "taken as a whole, lacks serious literary, artistic, political, or scientific value."

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