Educom Review, September/October 1998, p. 4

http://www.educause.edu/ir/library/html/erm9855.html

When a public library in Loudon County, Va., installed Internet filtering software on its library computers, patrons sued, saying the library was blocking their access to speech protected by the First Amendment.

In reviewing the cases during a hearing, the Federal District Court in Virginia agreed with the plaintiffs and held the library to the “strict scrutiny” standard of the First Amendment — a virtually impossible standard to meet since it requires any action by the State be made through the least restrictive method possible.