The three-pronged Miller test is for examining if something is obscene, which is a considerably narrower criteria than whether or not a given piece of free spee

The three-pronged Miller test is for examining if something is obscene, which is a considerably narrower criteria than whether or not a given piece of free speech is worthy of protection. Speech does not need to be 'valuable' to be worthy of protection, it needs to have a specific lack of value as determined by the Miller test to not be protected. Big difference.