Miller v. California
Headline: Court dismisses appeal in California obscenity conviction, leaving state law enforcement unchanged while dissenters say the statute’s broad definition of 'obscene' unlawfully restricts speech.
Holding: The Court dismissed the appeal for lack of a substantial federal question, leaving the California obscenity conviction and the challenged statute in place.
- Leaves the California conviction and state obscenity law in place for now.
- Suggests the defendant may seek a new trial to present local community standards evidence.
Summary
Background
A person was convicted in Orange County, California, for distributing what the State called "obscene matter" under California Penal Code §311.2 (1970). The statute defines "obscene matter" in §311(a) by whether the material appeals to prurient interest, exceeds customary candor, and lacks redeeming social importance. The state appellate court affirmed the conviction twice. The Supreme Court ultimately dismissed the appeal for lack of a substantial federal question.
Reasoning
The main question was whether California’s definition of "obscene matter" is constitutionally valid. Justice Brennan, joined by Justices Stewart and Marshall, dissented from the dismissal. He argued that the First and Fourteenth Amendments bar governments from completely suppressing sexually oriented materials in cases that do not involve juveniles or forced exposure. Brennan concluded that §311(a)’s definition is unconstitutionally overbroad on its face and therefore invalid. He would have reversed the state court judgment and ordered action to ensure the defendant could contest the legal standard used against him.
Real world impact
Because the Supreme Court dismissed the appeal, the conviction and the state statute remain in effect for now. The dissent warns that the law’s broad wording could suppress protected speech and says the defendant should get a chance to present evidence about the local community standards applied. The dismissal is not a final resolution on the statute’s constitutional validity and could be revisited in further proceedings.
Dissents or concurrances
Justice Douglas separately stated he would take jurisdiction and reverse, reflecting a wider disagreement among Justices about state bans on obscenity.
Opinions in this case:
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