The Supreme Court also explained that the California law "cannot be said to fall within those relatively few categories of instances where prior decisions have established the power of government to deal more comprehensively with certain forms of individual expression simply upon a showing that such a form was employed," including: The Supreme Court also explained that the California law "cannot be said to fall within those relatively few categories of instances where prior decisions have established the power of government to deal more comprehensively with certain forms of individual expression simply upon a showing that such a form was employed," including: Obscenity Fighting Words To protect unwilling or unsuspecting viewers All of the above