Obscenity in the United States can now be prosecuted under the standards of any community. From the article:

"We have this Balkanization under the 1st Amendment in regards to sexual speech," says John Wirenius, a lawyer for the plaintiffs in the case. "It's the only part of the 1st Amendment where there's no national standard. In obscenity alone, material can be free and protected in 49 of 50 states, but in one portion of one state it can be considered obscene and you can be prosecuted."

Follow link to Supreme Court declines to hear Nitke v. Gonzales
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