The test is known by 3 different names: The Miller Test The Three-Prong Standard SLAPS test
This test measures whether language can be labeled as "obscene" and will not be protected by the First Amendment and can even be prohibited. This test measures language compared to the values of the community and to the USA as a whole.
William Penn was more tolerant towards the Native Americans. He acknowledged the land that belonged to them and instead of forcefully taking away their land he bought it from them.