Hoyt v. Minnesota

Background

A Minnesota trial court and the Minnesota Supreme Court found certain printed materials obscene under a state law. The state’s enforcement efforts led to review by the U.S. Supreme Court. The high court agreed to hear the case and, without a full written opinion, granted the petition for review and reversed the state court’s judgment, citing the Court’s earlier decision in Redrup v. New York as controlling.

Reasoning

The central question was whether Minnesota could treat those materials as legally obscene in light of this Court’s prior rulings. The Court’s per curiam action applied its Redrup precedent and reversed the state judgment, ending the state’s effort to uphold that ban in this case. The practical result was that the challenged publications could not be suppressed under the state ruling the Court overturned.

Real world impact

This decision immediately affects people who publish, sell, or distribute the materials at issue by blocking state enforcement in this case. It limits one state’s ability to use that statute against these publications, and it signals that similar state bans may be vulnerable when earlier Supreme Court decisions, like Redrup, apply. The ruling was a summary reversal and so may not be a final, fully reasoned national rule.

Dissents or concurrances

Justice Blackmun, joined by the Chief Justice and Justice Harlan, dissented. They argued that the First and Fourteenth Amendments need not force a single national rule and that states should have flexible, reasonable power to regulate obscene products. They said Minnesota courts applied the state statute carefully and that a summary reversal was inappropriate at this unsettled stage.