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A variety of important proceedings have set the usual for obscenity rulings. This includes Miller v. California, which distinguished among obscenity and non-obscene elements. In addition to the Miller test, the Supreme Court has articulated a more common test to examine if anything is obscene. Chief Justice Warren Burger wrote that "the most tremendous implication is that various groups can articulate various group standards in obscenity cases. "In the case of pornography, a 3-part test was employed to determine regardless of whether it was obscene. First, the work must be patently offensive to the average person. Second, the work must lack severe literary or creative value. Third, the work must not have a substantial political or social impact. Although the first two parts of the Miller test were generally approved, the third part of the test was never as clear cut as it is today. Judges used their very own projections and present emotions to make a decision whether a piece of fabric was obscene.

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