In Memoirs v. Massachusetts, 383 U. S. 413 ( 1966 ), a plurality of the Court further redefined the Roth test by holding unprotected only that which is " patently offensive " and " utterly without redeeming social value ," but no opinion in that case could command a majority of the Court either, and the state of the law in the obscenity field remained confused.

In Memoirs v. Massachusetts, 383 U. S. 413 ( 1966 ), a plurality of the Court further redefined the Roth test by holding unprotected only that which is " patently offensive " and " utterly without redeeming social value ," but no opinion in that case could command a majority of the Court either, and the state of the law in the obscenity field remained confused.

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