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- The jury failed to reach a verdict and the judge declared a mistrial in the case of Dead Kennedys frontman Jello Biafra, who was accused of distributing harmful material to minors because of H. R. Giger's illustration “Work 219: Landscape XX”, known as “Penis Landscape”, which was included as a poster with the 1985 album “Frankenchrist”. It was the first case in which a musician was prosecuted over an album cover, and the costly trial contributed to the subsequent breakup of Dead Kennedys.