As concerns on the side effect of violent video games have increased since the tragedy of Columbine massacre in 1999, each states have tried to establish regulations on minors’ use of violent video games. Although several states’ legislation successfully passed regulatory acts which prohibited sales and rents of violent video games to minors, some associations of video game industry have brought these acts to federal courts which have authorities to review them by applying constitutional principles. The first judicial review case on a violent video game regulation act was American Amusement Machine Association v. Kendrick, in which federal judge Richard Posner confirmed that video game is also a kind of expression and that a violent expression should be protected under the First Amendment, contrary to an obscene expression. Interactive Digital Software Association v. St. Louis County of 2003 also followed the reasoning of Kendrick case, and these early landmark decisions of the federal appeal courts changed judicial way of thinking on violent video games. Following these legislations and judicial decisions, various state legislatures made regulatory acts against violent video games. However, every trial has failed by the federal district courts which succeeded to the Kendrick case. This confirmation process by the federal district courts on Kendrick holding has continued almost for 10 years. The consolidated holding of Kendrick was finally confirmed as a precedent by the Supreme Court last year. In Brown v. Entertainment Merchants Association, the Court concluded a normative debate on ongoing social issue, the harmfulness of violent video games on minors by holding that California’s regulation on violent video game is unconstitutional. This decision would be considered as a conclusion of a 10-year debate of federal district and appeal courts which have been led by some elite judges who acknowledged the value and importance of the freedom of expression in a democratic society.