The Naughty List: Remembering the Hayes Code of Porn

Jamie Elle eats something forbidden on the set  of "I Love Em Latin 3"
Jamie Elle eats something forbidden on the set of “I Love Em Latin 3”

It was 2000, and San Fernando Valley’s porn industry was scared. The Supreme Court had just declared George W. Bush President, and his choice of Attorney General was Missouri Governor John Ashcroft, popular with Bush’s Christian Conservative base. During the freewheeling 1990s of Bill Clinton, Big Porn had conquered the internet, and there was a feeling that Mom and Dad were coming home and the party was over.

Paul_J._Cambria,_Jr.That autumn, First Amendment attorney Paul Cambria received a simple, billable request from one of his Porn Valley clients. [It can now be revealed that client was former Video Team and Evil Angel exec Christian Mann, who passed away in 2014.] Cambria is one of the adult industry’s go-to lawyers for defense against obscenity charges — despite porn’s saturation then and now, an obscenity rap remains a very real threat.

“I was concerned with two things,” Cambria, now a senior partner at Buffalo’s Lipsitz, Green, Scime, Cambria, LLC, says. “What types of adult material were getting prosecuted, and where?”

In the month following the Supremes’ anointing of Bush, Cambria’s client asked his attorney to document some adult topics that might be vulnerable to the onslaught of obscenity litigation that the Porno-American community feared was just around the corner.

It became known as The Cambria List, and it ended up functioning as Porn Valley’s Hayes Code.

“I never called it ‘The Cambria List,'” says Cambria, whose 2001 itemization of “subjects most frequently selected for (obscenity) prosecution” was either referenced, ignored, or used as an excuse by porn producers who were wary or defiant of incoming Attorney General Ashcroft’s Department of Justice.

Incest. Rape. Certain Fluids. Even Interracial sex. These action items (or the suggestion of them) and many others have gone in and out of fashion in the porn marketplace. And Cambria noted that all of them had drawn obscenity charges in various counties across the United States.

“It wasn’t a list of things that I thought were obscene or not obscene,” Cambria says. “It was just what (had a history of) being prosecuted.”

But Cambria says that people often confused his data set with his personal preferences.

“What ended up happening was that people would say, ‘Well Cambria said not to do this or that.’ I took some guff for it.”

The List spread among Porn’s Los Angeles oligarchs, and soon its effects were being felt in studios around the Valley, spooking the traditionally insular industry. Porn Valley was less than a generation removed from the days when L.A. Vice cops would raid porn shoots, after all, and fear was in the air.

Filming actors “who happened to be having sex” was decriminalized with 1988’s landmark California v. Freeman. Prior to that, says Bob Chinn, director of numerous “Johnny Wadd” movies starring the late and legendary John Holmes, “we’d just tell the actors to meet us in a parking lot somewhere and then drive off in different cars in case the cops were out to bust us.”

But a dozen years of legality, Clinton, and the internet gave rise to some envelope-pushing. By 2000, men with names like Rob Black, Max Hardcore, and Khan Tusion were churning out product far more graphic and clinical than mainstream porn outlets like Vivid Video and Wicked Pictures, where stars like Jenna Jameson rarely messed up her hair. Khan Tusion’s “Rough Sex” series, for example, depicted women vomiting from forceful fellatio and getting toilet paper shoved in their mouths.

While tamer, couples-friendly, condom-wearing outfits like Wicked might have regarded Khan Tusion, et al as outliers, the extreme material was selling. This left establishment pornographers like Larry Flynt nervous that the DOJ was going to find some easy targets.

“We toned down the magazine drastically,” says Ernest Greene, editor of Hustler’s graphic fetish publication Taboo, which in 2001 had a circulation of 100,000. “For three years the proofs would come back with [Cambria’s] red-lines and annotations: ‘I would not do this.’

“Most people operated under an excess of caution,” Greene says, recalling a film he directed in which a man has just pulled his penis from a woman’s anus — which was fine — but then the woman looked at the penis for 12 seconds, waiting for it to be placed in her mouth — which would not have been fine, as Ass-to-Mouth (ATM) was “on the list.”

“I told my cameraman to cut away,” Greene says, “and we were instructed to cut those 12 seconds of anticipation of ATM.”

Cambria notes that Bush-era obscenity charges were not brought against “those who did not produce the material (listed),” but he also suspects that line items may have been added by certain producers “in (my) name.”

Like different interpretations of the Bible?

“Yes,” Cambria says. “The King James Version (of the list) was shorter.”

Regardless, the expected avalanche of DOJ obscenity charges did not materialize aside from a few high-profile cases. The first arrived shortly after Extreme Associates founder Robert “Rob Black” Zicari appeared on the PBS program “Frontline” in 2002 and issued a Bush-worthy “Bring it on.”

“We’ve got tons of stuff they technically could arrest us for,” Zicari said on TV. “I’m not out there saying I want to be the test case, but I will be the test case. I would welcome that. I would welcome the publicity.”

U.S. Attorney Mary Buchanan, who prosecuted Zicari and his then-wife, Janet “Lizzie Borden” Romano, said the “Frontline” interview was “very helpful for law enforcement to be able to assess what Rob Zicari’s intent was. What we learned from this interview is that Rob Zicari intended to violate federal law.”

Forced-Entry-Extreme-Cambria-PonantePosing as a website subscriber, a postal inspector in western Pennsylvania bought a 3-month membership to Zicari’s website and viewed clips from a section called The Piss Zone. Later inspectors purchased five DVDs from Extreme Associates, including the rape-with-retribution film “Forced Entry” (one-fifth of Zicari’s “Federal Five” that got him in trouble. The others were “1001 Ways To Eat My Jizz,” “Extreme Teen 24,” “Cocktails 2,” and “Ass Clowns 3.”

Zicari and Romano both did time after a series of court victories and reversals, as did pornographer Max Hardcore, who was convicted in Tampa (scenes of fisting, urination, vomiting) after an earlier acquittal in Los Angeles. All three have since been released from federal prison. Another Bush-era case, against Evil Angel founder John Stagliano (one of the offending films featured milk enemas), ended in a mistrial when DOJ operatives couldn’t get one of the movies to play on the judge’s DVD player. Stagliano and his legal team (including Cambria) celebrated outside the courtroom with champagne flutes filled with milk.

We can certainly find numerous examples of Cambria List items played out on websites these days, such as stretching vaginas, spitting mouth to mouth, “bukkake,” and wax dripping. Just last year, “Duke Porn Star” Belle Knox rose to fame with her scenes on the site, which regularly features irrumatio, or face-fucking.

Has something changed? Is it Obama?

“Certainly the mood of these two administrations has changed from one of litigation to regulation,” says Greene, pointing out the “worker safety” angle argued by supporters of Measure B, LA County’s Condoms in Porn law.

“But this has always been a self-regulating, self-policing industry,” adds Bruce Whitney, director of New Product Development for Adam & Eve Pictures. “Ever since Traci Lords forged her ID. The industry is full of people who want to make money and not break laws.”

While Whitney’s claim runs counter to Zicari’s tempting fate in 2002, it is true that there were two porn industries in the early aughts when it came to obscenity: The cautious businesspeople (Vivid, Wicked, Hustler, Adam & Eve) and the more extreme libertarians and/or iconoclasts who tended to get in trouble (Stagliano, Zicari, Hardcore). The Cambria List, such as it was, served as a gentle reminder to the former to not rock the boat. For people like Zicari it seemed more like a call to action.

“I have never heard of this list,” says director Jacky St. James.

St. James, who became an adult industry screenwriter in 2011 and whose movies have won numerous porn awards for her employer New Sensations, says she operates by “common sense” but also “can’t imagine a world in which interracial sex might be considered obscene.” (Speculating about this item on the list, Greene points out that it was an interracial scene in a 1978 issue of Hustler “that got Larry (Flynt) shot” by Joseph Paul Franklin.)

St. James says that her movies are distributed in a number of forms, such as via Video On Demand on sites like, but also as traditional DVDs, “and it is the distributor that says Yes or No” to the content.

For example, there is a scene in her “Sexual Liberation of Anna Lee” in which the main character is pictured bound at a clinic and her caregivers touch her sexually.

“I even made a point to have the character sign a waiver saying that her [caregivers] could do anything they wanted,” St. James says, “but [the distributor] thought it was too risky.”

Adam & Eve’s Whitney says all material created or distributed by his North Carolina-based company must first pass an internal review before being vetted further by a panel of three actual therapists.

“It’s got to be consensual, mutually beneficial, and [the panel] really pays attention to the characters’ sobriety,” he says. “There can be no intentional demeaning of women.”

[Indeed, former Adam & Eve contract star Carmen Luvana once told me that “I can call myself a dirty slut on camera, but if another person calls me a dirty slut, we have a problem.”]

There has been a winnowing of the porn industry in the past several years with the shrinking of the DVD market and the rise of internet piracy, but those who remain tend to cover their asses better, and to court danger less. The rise of ”parody porn” has made the industry particularly disclaimer-happy, with titles like “Love Boat XXX – A Parody” and “Not — ” or “This Ain’t — ” (every possible TV show or movie of the past 75 years, including “Not The Wizard of Oz XXX”). Of “Tabu Tales,” a series featuring what St. James calls Faux-cest , she says, “we make sure people know these are step-brothers and step-sisters and step-parents.”

Today the porn industry seems less worried about specific acts than whether or not it is clear that all parties depicted consent to them. Of the original items on the Cambria List, scenes with animals, children, or scatology remain outliers, and no one I know has seen evidence of the first two. Los Angeles fetish pornographer Ira Isaacs was convicted of the third in 2012.

Today the Cambria List can be seen as a menu of what was on offer at one time in the mainstream and outsider porn worlds: if it was on the list, you know someone once got in trouble for filming it. But things seem more relaxed now.

In Las Vegas I speak with the very white and very Welsh Sophie Dee, who is transitioning from busty porn star to busty scream queen in B-horror movies. She got into the porn industry in 2005 and quickly made a name for herself for her work in interracial movies. She doesn’t know about the Cambria List, either.

“No one ever arrested me for liking black cock,” she says.

I originally wrote parts of this story for and some of it appeared on

Previously on Porn Valley Observed: Stagliano rial sidelined by media errors; The Jizzful Cliff—lawyers file suit against Measure B; Podcast—Talkin’ hotwifin’ and fauxcest with Jacky St. James & Eddie Powell

About Gram the Man 4399 Articles
Gram Ponante is America's Beloved Porn Journalist


  1. I always wondered how a 12-second pause could prevent whatever gastrointestinal horrors that might happen with ATM.

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