In what circumstances have courts overturned convictions for obscene content?

In People v. Fritch (13 N.Y.2d 119, 243 N.Y.S.2d 1, 192 N.E.2d 713 (1963)), on the other hand, a book, 'Tropic of Cancer', was held obscene and an order reversing a conviction under section 1141 of the Penal Law was in turn reversed against the argument there was a resulting impairment of constitutional freedom to print. It was observed that there could be found 'a constant repetition of patently offensive words used solely to convey debasing portrayals of natural and unnatural sexual experiences' (13 N.Y.2d p. 124, 243 N.Y.S.2d p. 6, 192 N.E.2d p. 717).