The article I read was from an actual court transcript of a guy's conviction. I'm certainly not sure, but I think it was in New Jersey? East Coast for sure. 1990's
I had been transcribing someone else's case and read (as I typed) of the New Jersey? case. The defense argued that the defendant (who had a perfectly legal image of a child) had violated no laws because the image was not pornographic nor illegal in any way. The prosecution asked the defendant if he found the image sexually appealing. The defendant replied that he was sexually aroused by the photo. He was convicted of having child pornography. I read of the reference because it had been appealed. (If it was overturned or not, I don't recall.)
But that case was from 30 to 40 years ago in the States.