Carlson Et Al. v. Minnesota
Headline: Court vacates convictions for selling allegedly obscene books and films and sends the case back to Minnesota for reconsideration under recent Supreme Court obscenity decisions, affecting local sellers and exhibitors.
Holding: The Court granted review, vacated the Minnesota judgment, and remanded the case to the State Supreme Court to reconsider the obscenity convictions in light of the Court’s recent obscenity decisions.
- Requires Minnesota court to re-evaluate obscenity convictions for local booksellers and theaters.
- Leaves convictions unresolved until the state court reapplies recent Supreme Court standards.
- Raises the possibility that broad local bans could be struck down without specific exceptions.
Summary
Background
Petitioners were convicted in St. Paul for selling allegedly obscene books and displaying allegedly obscene motion pictures under a city ordinance that made it a misdemeanor to exhibit, sell, or offer to sell "obscene, lewd, lascivious or filthy" materials. The State defended the convictions below. The Supreme Court agreed to review the matter after issuing several major obscenity opinions earlier in the term.
Reasoning
The central question was whether these particular convictions remain valid in light of the Court’s recent obscenity rulings. The Supreme Court did not decide the merits. Instead it granted review, vacated the Minnesota judgment, and sent the case back to the Minnesota Supreme Court for further consideration in light of recent decisions such as Miller v. California and Paris Adult Theatre I v. Slaton. That means the state court must re-examine the case and apply the standards set out in those opinions.
Real world impact
The ruling leaves the underlying convictions unresolved for now and requires Minnesota’s highest court to re-evaluate prosecutions under the St. Paul ordinance. Local booksellers, adult theaters, and other sellers of sexually oriented materials are directly affected because their past or future prosecutions may be reexamined or altered depending on how the state court applies the new standards. The Supreme Court’s action is procedural, not a final decision on the constitutional questions, so outcomes could change on rehearing.
Dissents or concurrances
Two Justices dissented: Justice Brennan argued the ordinance is overbroad and would invalidate it absent showing distribution to minors or unconsenting adults; Justice Douglas relied on the private-possession ruling in Stanley v. Georgia and would reverse the convictions outright.
Opinions in this case:
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