In Jenkins v. Georgia, the U.S. Supreme Court ruled that a film could not be deemed obscene unless it was "patently offensive" and lacked any serious artistic, literary, political or scientific value. The case originated when theater manager Cecil Jenkins was convicted by a jury in Albany, Georgia for showing the film "Carnal Knowledge," which they found to be obscene under state law. However, the Supreme Court reversed this decision on appeal in 1974 with an unanimous vote of 9-0. They held that while states have broad power to regulate obscenity within their borders, such regulation must align with standards set forth by previous court decisions regarding what constitutes obscenity - specifically those outlined in Miller v California (1973). In applying these standards to "Carnal Knowledge", Justice William Rehnquist stated that no reasonable person would find the movie as a whole appealed only to prurient interest or depicted sexual conduct in an offensive way.

In the dissenting opinion for Jenkins v. Georgia, Justice Brennan disagreed with the majority's decision that upheld a state court ruling classifying a film as obscene and therefore not protected by First Amendment rights. He argued that this case was an example of how obscenity laws could be used to suppress free speech and expression arbitrarily, based on subjective interpretations of what constitutes "obscenity". He also criticized the Court's failure to provide clear guidelines about what content would fall under this category, which he believed led to inconsistent rulings across different jurisdictions. Furthermore, he expressed concern over potential chilling effects on artistic creativity due to fear of legal repercussions from such vague standards. In his view, only explicit sexual material without any serious literary or artistic value should be considered obscene and thus outside constitutional protection.