The Court recognized "a compelling interest in compensating victims from the fruits of the crime, but little if any interest in limiting such compensation to the proceeds of the wrongdoer's speech about the crime," Id. 502 U. S. at 120 21. The Court ruled that New York's "Son of Sam" law was inconsistent with the First Amendment because it was "overinclusive" in that it "reaches a wide range of literature that does not enable a criminal to profit from his crime while a victim remains uncompensated. " 502 U.
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1996 same; United States v. Seale, 20 F. 3d 1279, 1285 n. 7 3d Cir. 1994 dicta that Simon and Schuster does not prohibit fine that includes proceeds of expressive activity relating to crime, but rather prohibits the singling out of those proceeds for special treatment while ignoring other assets. Judicial reform is the complete or partial political reform of a country's judiciary. Judicial reform is often done as a part of wider reform of the country's political system or a legal reform. The President of the Constitutional Court of the Russian Federation, Valery Zorkin, gives in his article, "Twelve Theses on Legal Reform in Russia", first published in Russian magazine «Legislation and Economics», N. 2, 2004 an explained correlation between legal and judicial reform: "Complete legal reform should normally include not only judicial reform, but also reform of various aspects of the structural system and content of legislation, legal education, legal awareness by the population, and also the corporate consciousness of the whole legal community. Judicial reform usually aims to improve such things as law courts, procuracies, advocacy bar, inquest, executory processes, and record keeping. " .