Miller (1973):  Tired of the confusion the Roth standard
caused, the Court in this case forged a new definition of obscenity
built upon the Roth definition but which also resolved some
additional issues.  The Miller test stopped the trend, after Roth, of
increasing protection for obscenity, and the test remains the
modern-day approach to obscenity.  In this case, D mass mailed
brochures advertising for “adult” material.  Included in these
brochures were pictures and drawings of men and women in groups of
two or more engaging in a variety of sexual activities, with genitals
prominently displayed.  D was charged with violating a state
obscenity statute.  What is required for an obscenity statute not to
violate D’s First Am. rights?