mpanies such as Warner Brothers, Columbia, or MCA. For example, within a year after the PMRC hearings, a censorship case arose in Los Angeles involving Jello Biafra, the singer for the punk band known as the Dead Kennedys. Jello Biafra was the owner of a small independent recording label that featured his own group as well as several others. The 1985 album Frankenchrist by the Dead Kennedys included a poster which was based on a painting by an artist named H. R. Giger. Although Giger is generally esteemed as a serious artist, the particular work chosen for the poster was "Penis Landscape," and there was little doubt in anyone's mind that it was shockingly obscene. In fact, Biafra had intentionally chosen to include the poster in his album because he wanted to shock his audience. However, he was arrested and charged with contributing to the delinquency of a minor when a record store sold the album to a person under the age of eighteen (Wishnia, 1987, p. 444). Following a lengthy trial, Jello Biafra was finally acquitted of this charge. Neverthe
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