No two writers are the same. Writing is both an art and a science. Whereas the
technical correctness of a sentence can be quantified, assessing the quality of hundreds of
words, each of individual denotation, grafted together into an essay of unique connotation
and voice remains an elusive task. Just as Justice Potter Stewart’s statement, “I know it
when I see it.” (Jacobellis v. Ohio, 1964) failed to provide an objectively measurable
standard for obscenity in film, it did capture the difficult, seemingly impossible task of
reducing a creative work down to a single adjective: obscene or tasteful, bad or good.