In Mauro v. Arpaio, 188 F.3d 1054 (9th Cir. 1999), inmates challenged a policy prohibiting inmates from possessing "sexually explicit material," defined as materials that show frontal nudity. The policy was aimed at reducing the sexual harassment of female officers. In the past, inmates had used the nude photographs: (1) to openly masturbate in front of female officers; (2) to draw anatomical comparisons between the persons depicted in the photographs and female officers. the United States Court of Appeals for the Ninth Circuit (Ninth Circuit) held that, although no court had addressed whether reducing sexual harassment of prison employees by inmates is a legitimate penological interest, it is a legitimate interest.