In the 1970 case of Grove Press, Inc. et al. v. Maryland State Board of Censors, the U.S Supreme Court ruled in favor of Grove Press, Inc., a publishing company that had been denied permission to distribute its film "I Am Curious (Yellow)" by the Maryland State Board of Censors due to its explicit sexual content. The court held that under the First Amendment's protection for freedom of speech and expression, states could not ban films solely based on their explicit content unless they were deemed obscene according to contemporary community standards - which this film was not found to be after review by lower courts. This ruling reaffirmed previous decisions upholding free speech rights against state censorship efforts and clarified how obscenity laws should be applied in relation to films.

In the dissenting opinion for Grove Press, Inc. v. Maryland State Board of Censors, the justice argued that states should have the power to regulate obscene material and protect their citizens from exposure to such content. The justice contended that obscenity is not protected by First Amendment rights and therefore can be subject to state regulation without infringing on constitutional freedoms. They also expressed concern about potential harm caused by explicit materials, particularly in relation to minors or those who might unwillingly encounter them. Furthermore, they disagreed with the majority's view that only hardcore pornography could be regulated as obscene under federal law; instead arguing for a broader interpretation of what constitutes obscenity which would allow states more leeway in regulating potentially harmful content.