Obscene material is not inherently protected speech, but as it's a content-based restriction, the government is still bound by strict scrutiny to narrowly tailo

Obscene material is not inherently protected speech, but as it's a content-based restriction, the government is still bound by strict scrutiny to narrowly tailor its laws to achieve its legitimate interest in limiting the distribution of pornography. Furthermore, the definition of obscenity (the Miller test) is actually rather narrow, and there are likely to be several sexual fetishes that don't actually qualify as obscene, and therefore protected speech.