The first is "mere nudity" as upheld in "Jenkins v. Georgia, 418 U.S. 153 (1974)" whereby the film Carnal Knowledge was deemed not to be obscene under the constitutional standards announced by Miller.
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Many historically important works have been described as obscene or prosecuted under obscenity laws, including the works of Charles Baudelaire, Lenny Bruce, William S. Burroughs, Allen Ginsberg, James Joyce, D. H. Lawrence, Henry Miller, Samuel Beckett, and the Marquis de Sade.
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The most notable films given an "X" rating were Deep Throat (1972) and The Devil in Miss Jones (1973).
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