Obscenity trial of Ulysses in The Little Review  

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Kunstformen der Natur (1904) by Ernst Haeckel
Kunstformen der Natur (1904) by Ernst Haeckel

The obscenity trial over the publication of James Joyce’s Ulysses in The Little Review, an American literary magazine, occurred in 1921 and effectively banned publication of Joyce's novel in the United States. After The Little Review published the "Nausicaa" episode of Ulysses in the 1920 July–August issue of the magazine, the New York Society for the Suppression of Vice instigated obscenity charges against Little Review editors Margaret Caroline Anderson and Jane Heap. The editors were found guilty under laws associated with the Comstock Act of 1873, which made it illegal to circulate materials deemed obscene in the U.S. mail. Anderson and Heap incurred a $100 fine, and were forced to cease publishing Ulysses in The Little Review.

Precedents in obscenity law

Legal conceptions of obscenity which influenced Anderson and Heap’s trial go back to an obscenity standard first articulated in the 1868 English case of Regina v. Hicklin. In this case, Lord Chief Justice Cockburn defined the "test of obscenity" as "whether the tendency of the matter charged as obscenity is to deprave and corrupt those whose minds are open to such immoral influences, and into whose hands a publication of this sort may fall."

This standard, known as the Hicklin test, went on to influence American jurisprudence, first in United States v. Bennett (1879), upholding a court charge based upon the Hicklin obscenity test and allowing the test to be applied to passages of a text and not necessarily a text in its entirety. Following this, the Hicklin test was endorsed by the U.S. Supreme Court in Rosen v. United States (1896) and was adhered to by American courts well into the twentieth century.

In 1873, after the lobbying attempts of Anthony Comstock, head of New York Society for the Suppression of Vice, the U.S. Congress amended a pre-existing law and enacted the Comstock Act, which made it a crime to knowingly mail obscene materials or advertisements and information about obscene materials, abortion, or contraception. This act adopted the Hicklin test for deeming which materials would be considered obscene.


The U.S. Post Office confiscated the October 1917 issue of The Little Review due to the publication of Wyndham Lewis’ story "Cantleman’s Springmate", which focuses on a young, disillusioned soldier who, while awaiting deployment to the front lines of World War I, seduces a young girl and afterwards ignores her letters informing him of her pregnancy. The story was seized due to its perceived sexual lewdness and anti-war sentiments which were thought to violate the Comstock laws prohibiting “obscene, lewd, or lascivious” material from being mailed. John Quinn, a successful lawyer and patron of the arts who was benefactor to both The Little Review and Ezra Pound, the magazine’s foreign editor at the time, believed the magazine to have been suppressed due to editors Anderson and Heap’s support of anarchists Emma Goldman and Alexander Berkman and anti-war statements they published in New York newspapers. Their support of radical political figures had already led to their eviction from their New York studio office.

Following this suppression, it was difficult for Anderson and Heap to find a New York printer willing to print episodes of Ulysses. When they found a printer, The Little Review began its serialization of Ulysses, publishing the first episode from the work in March, 1918. Following this first publication of Ulysses, three issues of The Little Review were seized and burnt by the U.S. Post Office on the grounds that its prose was deemed 'obscene'. The January 1919 issue which contained the "Lestrygonians" episode of Ulysses was the first that was seized; the May 1919, which contained "Scylla and Charybdis," was second; and the January 1920 issue, which contained the "Cyclops" episode, was third.

In 1920, a New York attorney whose daughter had received an unsolicited copy of The Little Review issue containing the "Nausicaa" episode of Ulysses brought it to the attention of John S. Sumner, secretary of the New York Society for the Suppression of Vice. Sumner lodged a complaint in September 1920, and on October 4 Anderson and Heap were arrested and charged with obscenity for publishing "Nausicaa" in the 1920 July–August issue of The Little Review. This episode was an account of protagonist Leopold Bloom fantasizing about a young girl named Gerty MacDowell who leans back to expose herself to Bloom. The scene culminates in Bloom’s orgasm, which legal historian Edward de Grazia, in Girls Lean Back Everywhere, argues would have likely escaped the average reader's notice due to Joyce’s metaphorical language.

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