State v. Watkins

203 S.E.2d 429, 262 S.C. 178, 1973 S.C. LEXIS 207
CourtSupreme Court of South Carolina
DecidedNovember 26, 1973
Docket19727
StatusPublished
Cited by8 cases

This text of 203 S.E.2d 429 (State v. Watkins) is published on Counsel Stack Legal Research, covering Supreme Court of South Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Watkins, 203 S.E.2d 429, 262 S.C. 178, 1973 S.C. LEXIS 207 (S.C. 1973).

Opinion

Littlejohn, Justice:

This case has been before this Court heretofore, resulting in our opinion affirming a conviction in State v. Watkins, 259 S. C. 185, 191 S. E. (2d) 135 (1972). Thereafter, Watkins appealed to the Supreme Court of the United States. It was among more than 50 cases involving the Law of Obscenity. The United States Supreme Court disposed of the appeal b)r ordering “that the judgment of the Supreme Court of South Carolina in this cause be vacated, and that this cause be remanded to the Supreme Court of the State of South Carolina for further consideration in light of Miller v. California, 413 U. S. 15, 93 S. Ct. 2607, 37 L. Ed. (2d) 419 (1973); Paris Adult Theatre *180 I V. Slaton, 413 U. S. 49, 93 S. Ct. 2628, 37 L. Ed. (2d) 446 (1973); Kaplan v. California, 413 U. S. 115, 93 S. Ct. 2680, 37 L. Ed. (2d) 492 (1973); U. S. v. 12 200-ft. Reels of Super 8mm Film, 413 U. S. 123, 93 S. Ct. 2665, 37 L. Ed. (2d) 500 (1973); U. S. v. Orito, 413 U. S. 139, 93 S. Ct. 2674, 37 L. Ed. (2d) 513 (1973); Heller v. N. Y., 413 U. S. 483, 93 S. Ct. 2789, 37 L. Ed. (2d) 745 (1973); Roaden v. Ky., 413 U. S. 496, 93 S. Ct. 2796, 37 L. Ed. (2d) 757 (1973); and Alexander v. Virginia, 413 U. S. 836, 93 S. Ct. 2803, 37 L. Ed. (2d) 993 (1973).” (Citations Added.)

We now proceeded to dispose of the case, keeping in mind Miller, Paris Adult Theatre, and other opinions cited by the United States Supreme Court. The Court has consistently held both before and in Miller and in Paris Adult Theatre that obscenity is not protected by the First Amendment to the Constitution of The United States.

In Miller there was involved a statute of the California Legislature which defined obscenity as follows:

“ ‘Obscene’ means that to the average person, applying contemporary standards, the predominant appeal of the matter, taken as a whole, is prurient interest, i. e., a shameful or morbid interest in nudity, sex, or excretion, which goes substantially beyond customary limits of candor in description or representation of such matters and is matter which is utterly without redeeming social importance.”

In Paris Adult Theatre there was involved a statute of the Georgia Legislature which defined obscenity as follows:

“Material is obscene if considered as a whole, applying community standards, its predominant appeal is to prurient interest, that is, a shameful or morbid interest in nudity, sex or excretion, and utterly without redeeming social value and if, in addition, it goes substantially beyond customary limits of candor in describing or representing such matters. ...”

*181 In the case before us there is involved a statute of the South Carolina Legislature which defines obscenity as follows:

“ ‘Obscene’ means that to the average person, applying contemporary standards, the predominant appeal of the matter, taken as a whole, is to pruient interest among which is a shameful or morbid interest in nudity, sex or excretion, and which goes substantially beyond customary limits of candor in description or representation of such matters. . . .”

It is readily observed that the statutes of the three states undertaking to define obscenity are amazingly similar. 1 It is obvious that the legislature in all three states strove to enact a law compatible with the ruling in Roth v. United States, 354 U. S. 476, 77 S. Ct. 1304, 1 L. Ed. (2d) 1498 (1957). The principal difference between the South Carolina statute on the one hand and the California and Georgia statutes on the other hand lies in the omission of utterly without redeeming social value (or importance) in our statute.

Such omission from the South Carolina statute is without real meaning, and we think that the three statutes have the same constitutional footing. No constitutionally valid argument can be made that one of the three should stand and another fall. In Miller the majority opinion of Chief Justice Burger said:

“We do not adopt as a constitutional standard the ‘utterly without redeeming social value’ test of Memiors (sic) v. Massachusetts, supra, 383 U. S. [413], at 419, 86 S. Ct. [975], at 977 [16 L. Ed. (2d) 1] (1966); that concept has never commanded the adherence of more than three Justices at one time.”

*182 Notwithstanding the fact that our statute did not require that material be “utterly without redeeming social value” warrant a conviction, the trial judge charged the jury that before a conviction could be had it must find “that the material is utterly without redeeming social value.” Watkins was given the, benefit of this charge and should not be heard to complain. The charge was more favorable to Watkins than a charge required by Miller to the effect that in order to warrant a conviction a jury must find that the work, taken as a whole, lacks serious material, artistic, political, or scientific value.

The absence of Miller specificity did not render the Georgia statute and the California statute unenforceable or unconstitutional. By a similar token, our statute is not unenforceable or unconstitutional. It is significant that the statutes of California and of Georgia were not invalidated, and the judgments were vacated but not reversed. In Paris Adult Theatre the Court said:

“In this case we hold that the States have a legitimate interest in regulating commerce in obscene material and in regulating exhibition of obscene material in places of public accommodation, including so-called ‘adult’ theatres from which minors are excluded. In light of these holdings, nothing precludes the State of Georgia from the regulation of the allegedly obscene materials exhibited in Paris Adult Theatre I or II, provided that the applicable Georgia law, as written or authoritatively interpreted by the Georgia courts, meets the First Amendment standards set forth in Miller v. California, supra, 413 U. S. [15] at pp. 23-25, 93 S. Ct. [2607] at pp. 2614-2616 [37 L. Ed. (2d) 419].”

We quote the First Amendment standards from Miller as follows:

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Town of Mount Pleasant v. Chimento
737 S.E.2d 830 (Supreme Court of South Carolina, 2012)
People v. Neumayer
275 N.W.2d 230 (Michigan Supreme Court, 1979)
Commonwealth v. MacDonald
347 A.2d 290 (Supreme Court of Pennsylvania, 1975)
State v. Thompkins
211 S.E.2d 549 (Supreme Court of South Carolina, 1975)
Mangum v. Maryland State Board of Censors
328 A.2d 283 (Court of Appeals of Maryland, 1974)
Watkins v. South Carolina
418 U.S. 911 (Supreme Court, 1974)
State v. Bryant
203 S.E.2d 27 (Supreme Court of North Carolina, 1974)

Cite This Page — Counsel Stack

Bluebook (online)
203 S.E.2d 429, 262 S.C. 178, 1973 S.C. LEXIS 207, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-watkins-sc-1973.