Memoirs v. Massachusetts
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Memoirs v. Massachusetts, 383 U.S. 413 (1966), is a United States Supreme Court decision that attempted to clarify a holding regarding obscenity made a decade earlier in Roth v. United States (1957).
The Roth ruling established that for a work of literature to be considered obscene, it had to be proven by censors to: 1) appeal to prurient interest, 2) be patently offensive, and 3) have no redeeming social value. The literature in Roth v. United States was Fanny Hill (or Memoirs of a Woman of Pleasure, 1749) by John Cleland and the Court held in Memoirs v. Massachusetts that, while it might fit the first two criteria (it appealed to prurient interest and was patently offensive), it could not be proven that Fanny Hill had no redeeming social value. The judgment favoring the plaintiff continued that it could still be held obscene under certain circumstancesTemplate:Snd for instance, if it were marketed solely for its prurient appeal.
The Memoirs standard for obscenity prompted ongoing debate over the definition of obscenity and was superseded by the Supreme Court's 1973 decision in Miller v. California, which established the Miller test, a more flexible three‑prong test based on local community standards.
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