that a State's interest in safeguarding the physical and
psychological well-being of a minor is compelling.") (internal
quotation marks and citation omitted); Ginsberg, 390 U.S. at 640
("The State . . . has an independent interest in the well-being
of its youth.").


The government's compelling interest in protecting the well-
being of its youth justifies laws that criminalize not only the
distribution to minors of material that is harmful to minors, but
also the possession and distribution of child pornography.
See Osborne v. Ohio, 495 U.S. 103, 111 (1990) (holding that a
state "may constitutionally proscribe the possession and viewing
of child pornography"); Ferber, 458 U.S. at 757, 763 (noting that
"[t]he prevention of sexual exploitation and abuse of children
constitutes a government objective of surpassing importance," and
holding that "child pornography [is] a category of material
outside the protection of the First Amendment").
Thus, a public library's use of software filters survives
strict scrutiny if it is narrowly tailored to further the state's
well-recognized interest in preventing the dissemination of
obscenity and child pornography, and in preventing minors from
being exposed to material harmful to their well-being.
2. Protecting the Unwilling Viewer
Several of the libraries that use filters assert that
filters serve the libraries' interest in preventing patrons from
being unwillingly exposed to sexually explicit speech that the
patrons find offensive. Nearly every library proffered by either
the government or the plaintiffs received complaints, in varying
degrees of frequency, from library patrons who saw other patrons