How have the courts interpreted the term "lewd acts" in the context of lap dancing?

Since we resolve this case on obscenity grounds, we need not decide whether the otherwise vague statutory term "lewd acts" must be subjected to further judicial construction in the context of clothed individuals. Had the parties not tied this appeal up to a First Amendment mooring, we might have set sail with a well-reasoned opinion from the "Show Me state" on facts like our own. In State v. Burgess (Mo.App.1984) 669 S.W.2d 637, the court reversed the prostitution conviction of a lap dancer who stood on a chair in front of a patron and performed a "series of hip gyrations and squatting movements" that the court likened to the "not-so-modern erotic dance routine commonly labeled 'bumps and grinds.' " (Id. at p. 638.) Since she was a "dancer[ ], not [a] magician[ ]," the patron periodically touched her buttocks and thighs to steady her while she rubbed her genitals (covered by a scanty bikini bottom) over his nose and face. (Ibid.) The pertinent Missouri statutes defined "prostitution" as "any touching, manual or otherwise, of the anus or genitals of one person by another, done for the purpose of arousing or gratifying sexual desire of either party" in which a payment was involved. (Id. at p. 639.)