Disclaimer: I have no interest in Lolicon/Shotacon. I am 100% against all cases of abuse and exploitation against children, both physically and material wise, and I fully support and advocate for their protection and safety.

NOTE: Common words based on the topic of this article will use alternative words to avoid controversy or unfair cuts due to issues and incidents with companies.

It was the year 2006. During that year, anime airing on American television stations, most notably, Toonami/Adult Swim, were rocking the country. Anime hits like Naruto, Bleach, and other anime were taking the American otaku world by storm. Anime con attendances were rising, distributions were increasing, and popularity of anime and manga as a whole, thanks to the rise of fan subs on the internet, and the numbers were significantly rising in numbers. In other words, it was a turning point for American history of anime and manga. Meanwhile in Japan, often regarded by many (including myself) as the greatest year in anime history, saw the airings of a great amount of legendary anime during that year. The Melancholy of Haruhi Suzumiya, Death Note, and Code Geass. All aired on that same year, and to this day, are still beloved among both the otaku, and the mainstream viewer. As of today, such legends are still talked about as if they were brand new. Also, my favorite anime of all time, Kanon, aired on that year, and is still my favorite even after 14 years when I first watched it back in 2011.

But would you believe me if I were to tell you on that same year, a legal case was about to commence in 2006 that would not only rock much entertainment based communities, like comics, cartoons, movies, TV shows, and, yes, anime and manga as a whole, but an entire legal system here in America? In May 2006, a case known as United States v. Handley was about to occur that would become a cautionary tale for otakus, anime and manga fans, and fans of fiction like comic books, and cartoons in general.

In May 2006, a man from Iowa by the name of Christopher Handley was arrested. Reasons for his arrest were based on a postal interception of a package delivered to his home location. Authorities suspected that his package contained cartoon imagery of objectional content. This would eventually lead to a search warrant for Handley’s home. During the scene, authorities seized over 1,2000 items. His items ranged from a numerous amount of items. From anime DVDs, manga books, and seven computers. Basically, what an otaku would typically collect. However, the kicker of what would ultimately lead to his arrest was authorities finding at least 80 items of what they identified as “drawings of children being sexually abused.” Perhaps a notable part about the findings was the fact that most of these items are from a manga anthology by the name of Comic LO. A lolicon manga anthology magazine. The magazine still operates as of 2025. During the search, Handley had no possession of photographic “CP”. All findings were fictional drawings.

Despite this, Handley was charged under the PROTECT Act of 2003 Prosecutorial Remedies and Other Tools to End the Exploitation of Children Today Act), specifically 18 U.S.C. § 1466A. This law criminalizes obscene visualization representation of the sexual abuse of children. This includes drawings or computer generated images that appear to depict minors in sexually explicated conduct. Enforced by the law, Handley faced changes for recieving and possessing material obscene materials and as well as mailing obscene material. He faced a potential maximum sentence of 15–20 years in prison and a $250,000 fine.

However, two years after the conviction, in 2008, Handley filed a motion to dismiss the charges. His argument was based on the relevant provision that the Protect Act of 2003 (18 U.S.C. § 1466A(a)(2) and (b)(2)) violated the first amendment and fifth amendment by restricting free speech and being overly vague. His argument of defense was the drawings were fictional characters and not deceptions of real children, and thus should be protected under the first amendment. Handley cited the surpreme court’s 2002 ruling, known as Ashcroft v. Free Speech Coalition. That decision had struck down parts of the “CP prevention act of 1996”. It was ruled by the court that virtual CP (not involving real children), could not be criminalized unless it met the obscenity standards established in Miller v. California (1973).

In July 2008, District Judge James E. Gritzner Partially agreed with Handley’s motion. He ruled that 18 U.S.C. § 1466A(a)(2) and (b)(2) were ruled unconstitutional because they criminalized protected speech without requiring the materials to meet the Miller test for obscenity. In a more detailed meaning, it means in to, (which evaluates whether material lacks serious literary, artistic, political, or scientific value, appeals to prurient interest, and is patently offensive by community standards). Despite this, Gritzner upheld the charges under 18 U.S.C § 1466A(a)(1) and (b)(1), which required the materials to be obscene under the Miller test, leaving it to a trier of fact (e.g., a jury) to determine obscenity.

In 2009, With Handley finding himself facing a mandatory minimum of five years if convicted at trial, Handley then opted for a plea deal. In 2010, he pleaded guilty to possessing obscene visual representations of the sexual abuse of children and mailing obscene material. After the plea deal, Handley was then sentenced to six months in jail, three years of supervised release, and five years of probation. On the bright side, he was not required to register as a sex offender. Unfortunately, he had to forfeit his entire manga collection, including non-obscene material, and had to undergo psychological testing and treatment during his supervised release.

Both sides had their fair share of statements in regard to this case. The prosecution argued that Handley’s possession of lolicon manga indicated a “sexual deviancy” requiring imprisonment and treatment. This is despite, Handley’s lack of criminal history and the absence of possessing of real “CP.” The prosecution also argued Handley’s possession of material lacked any literary, artistic, or scientific value. They also unfavorably compared them to well known works of literature, like Lolita, and Lost Girls. Meanwhile, the defense argued that Handley’s possession of lolicon manga was a minute portion of Handley’s vast, encyclopedic collection and that posed no threat to his community. The defense also highlighted culture differences. They argued that Japanese manga often features stylized characters that may appear youthful due to artistic conventions (e.g., large eyes, lack of pubic hair), which can be misinterpreted by U.S. authorities unfamiliar with the medium.

Following the aftermath of the case. Christopher Handley’s case became the first in the U.S. to be charged by the PROTECT Act solely for possessing obscene manga. Without any real “CP”, or harm to an actual person. The case caused a massive domino effect not just among the American anime and manga community, but for many other communities based on art or animation like comics or cartoons. The major concerns were U.S. obscenity laws to Japanese media, which is known for its different cultural norms and functions as opposed to U.S. cultural norms and functions. Specifically in regard to nudity and sexuality. Primary criticism to the case mainly boils down to the prosecution’s full targeting of Handley’s tastes rather than criminal behavior. Most notably, his collection was seized indiscriminately by authorities, which also including non-obscene materials despite the case revolving around discriminate material.

Two years later in 2011, the ruling was later challenged in United States v. Dean (2011), a case in the Eleventh Circuit Court of Appeals, which questioned Gritzner’s finding that parts of the PROTECT Act were overbroad. The Dean case suggested that Handley’s defense failed to prove “substantial overbreadth,” leaving the legal status of such provisions uncertain.

One of the notable stories of this case was the direct involvement of the CBLDF. Also known as Comic Book Legal Defense Fund. Providing financial support and legal consultation through attorney Eric Chase. The CBLDF argued that Handley’s prosecution distorted the purpose of “CP laws, which are intended to protect real victims, not to criminalize fictional drawings. The non-profit organization argued and emphasize Handley’s case as a troubling precedent, prosecuting individuals based on private possession of art and the thoughts they have while viewing it.

There you have it, my fellow otakus. This was the story of United States v. Handley. This was a very important story for the American otaku simply because it created a wave of uncertainty for many. The interesting part was, it wasn’t just anime and manga fans that were concerned, but even non fans of other pieces of entertainment were concerned, as many feared that their pieces of entertainment would be affected by this ruling as well. Not only that, but this is a piece of history very important among us, as it represented a time when people were mostly ignorant about how anime and manga. Many assumed that just because an anime girl had big eyes, a young look, and wore cute clothes, some people automatically assumed that this character was a minor. Many did not educate themselves on how different anime and manga characters are drawn in Japanese comic style as opposed to other comic art in America and other nations worldwide. Cultural norms from Japan were at odds with American cultural norms. Even outside the sexual hemisphere of anime and manga, the controversy was still the same. Remember how Pokémon, and Dragon Ball stirred such controversy and were falsely accused of evil entities that were completely false. In my opinion, the case didn’t make any sense at all. Especially how Handley had to forfeit his non-obscene material despite the fact that material like that was already in anime cons, available to buy online and was not even illegal in the first place. Hence, why this court case was such an important one for many. Not only that, but it’s obvious that while this prosecution tried to do it with good intentions, it was clearly obvious that it was more based on ignorance rather than knowledge. Evidence show that the defense had the same rightful reasoning as well. Many at the time, and still are, (just not as ignorant), still do not know how anime and manga functions as a whole. The sad part is, laws, and cases like these mentioned before, are still happening. Especially with the recent censorship crackdowns happening in America, and worldwide. The dedicated and passionate actions of many non-profit organizations, like CBLDF, demonstrate the importance and need for organizations that protect freedom of creativity and freedom of speech. As stated before, real children being harmed by individuals for any sinister reason, be it predatory or any reason, must be stopped, denounced, prosecuted, and enact justice. The problem is, some people are ignorant or poorly informed over entertainment that involves art. Many believing that it should still be for children when, in reality, it’s for all ages. Like other pieces of entertainment, animation like anime, manga, comics, or cartoons, all have their specific age ratings, and it’s parental responsibility to know which is right and wrong. Here’s the thing… Handley wasn’t the only one who went through this… There are plenty of other cases where such events like these happened. Unlike Handley, some have suffered harsher convictions worldwide, which makes the case for legal battle in protection of free speech and freedom of creativity. Even then, despite it being more than two decades ago, uncertainty still lingers… With the recent censorship issues, the fight goes on…

Thank you for reading this! I hope you enjoyed it, and stay tuned for more!

Also read: The 2025 Internet Censorship Crisis: What’s going on

Sources: Wikipedia 1–2, Forbes, CBR, Justia, Anime News Network, CBLDF 1–2,