The Entertainment Software Association (ESA) scored a victory after Michigan Court District Judge George Caram Steeh ruled that the state's video game law restricting the sale of violent games to minors is unconstitutional and therefore cannot be implemented.

Judge Steeh did not agree with the state of Michigan's claims that "video games' interactive nature made them less entitled to protection under the First Amendment."

Steeh explained: The interactive, or functional aspect, in video games can be said to enhance the expressive elements even more than other media by drawing the player closer to the characters and becoming more involved in the plot of the game than by simply watching a movie or television show. It would be impossible to separate the functional aspects of a video game from the expressive, inasmuch as they are so closely intertwined and dependent on each other in creating the virtual experience.  In November last year, Steeh handed down a temporary injunction against the law.

According to Judge Steeh, the state of Michigan failed to show evidence that there is a direct relationship between violence in video games and violence acted out by kids and teens. The studies provided by Dr. Craig Anderson in support of the bill also failed to distinguish video games from other forms of media, making it impossible to single out video games as a cause of aggressive behavior in minors. Steeh also shot down the notion that video games are far worse than other media, stating that the video game is an outlet for minors to vent anger or violent behavior, which decreases the chance they are acted out in reality.