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Because it allows for community standards and demands " serious " value, Justice Douglas worried in his dissent that this test would make it easier to suppress speech and expression.
Miller replaced a previous test asking whether the speech or expression was " utterly without redeeming social value ".
As used, however, the test generally makes it difficult to outlaw any form of expression.
Many works decried as pornographic have been successfully argued to have some artistic or literary value, most publicly in the context of the National Endowment for the Arts in the 1990s.

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