A fantastic page turner traces the 1921 Ulysses trial (and its echoes in today’s censorship wars)
A Danger to the Minds of Young Girls: Margaret C. Anderson, Book Bans, and the Fight to Modernize Literature | Adam Morgan | Atria/One Signal Publishers (288 pages)
Dress Code: Demure and Silent
On February 14, 1921, lawyer John Quinn orchestrated a piece of courtroom theater that would have made any trial consultant proud. His clients — Margaret C. Anderson and Jane Heap — had been serializing James Joyce’s Ulysses in their avant-garde magazine The Little Review, and now they were facing obscenity charges. Quinn seated the two lesbian publishers among a carefully curated audience of “quietly-dressed women and innocent boarding-school girls.” He instructed Anderson to appear “inconspicuous, meek and silent” throughout the proceedings.
The gambit worked brilliantly. When prosecutors wanted to read aloud the “obscene” passage, one judge refused, looking protectively at Anderson. “I’m sure she didn’t know the significance of what she was publishing,” he declared.
It was the perfect con: neutralize the prosecution’s attack on the dangerous “new woman” by making Anderson look like one of the innocent girls supposedly in need of protection.
There was just one problem: Quinn despised his clients.
The Lawyer Who Saved the Book But Threw the Women Under the Bus
This is one of many riveting details in Adam Morgan’s essential new biography A Danger to the Minds of Young Girls: Margaret C. Anderson, Book Bans, and the Fight to Modernize Literature (Atria/One Signal Publishers, 288 pages). Morgan’s comprehensive account traces Anderson’s journey from privileged Indiana upbringing to founding The Little Review in 1914, championing experimental writers like T.S. Eliot, Ezra Pound, and Djuna Barnes, and her numerous creative and romantic relationships with women. But what makes this book so timely now is Morgan’s meticulous reconstruction of the 1921 obscenity trial — a case that feels less like history and more like a preview of coming attractions.
Quinn was a wealthy arts patron desperate to ensure Ulysses could be published in America. If the book was ruled obscene, that dream died. But Anderson and Heap being lesbians? He called them “rabbits” with palpable disdain. Quinn wasn’t their champion — he was the book’s champion. And his strategy reflected that cold calculation.
Quinn’s Strategy: Beat Paternalism With More Paternalism
When his first approach failed — arguing that Joyce was a genius comparable to Dante and Shakespeare — the judges dismissed it immediately. They weren’t interested in literary merit. They wanted to know one thing: did it violate the Comstock Act?
So Quinn pivoted to a more creative defense: the book was incomprehensible. He called literary critic John Cowper Powys to testify that Ulysses was an “experimental, tentative, revolutionary work” that was “too obscure and philosophical to be in any sense corrupting,” comparing it to cubist paintings. Quinn spent half an hour explaining how Joyce’s lack of punctuation made the book impenetrable.
Margaret later recorded in The Little Review one judge’s bewildered response: “It sounds to me like the ravings of a disordered mind.”
When witness Philip Moeller invoked Freudian concepts, Chief Justice Frederic Kernochan interrupted in exasperation: “I don’t understand what this man is talking about… He might as well be talking in Russian.”
Morgan’s reconstruction of these courtroom moments is so sharp, so alive, you can practically hear the judges’ exasperation. He captures the impossible gulf between modernist innovation and the legal system’s rigid obscenity definitions. The judges didn’t care about Joyce’s stream of consciousness or interior monologues. Was it dirty? That’s all that mattered.
When “Protecting Young Girls” Meant Silencing Women
The prosecution was led by John S. Sumner, head of the New York Society for the Suppression of Vice (NYSSV). His stated mission? Protecting “the minds of young boys and girls from filth.” The NYSSV was a private organization that worked with the police as an unofficial adjunct to the District Attorney’s office. Basically, the DA outsourced censorship. I’m still not sure how that’s legal.
The facts: Anderson and Heap serialized Joyce’s Ulysses in The Little Review. Sumner charged them under the Comstock Act for publishing the “Nausicaa” episode, featuring Gerty MacDowell, which was deemed “obscene and lewd.” And here’s what Anderson faced: loss of her postal license (meaning she couldn’t mail out her magazine) and up to 20 years in prison. The stakes were existential.
The stated goal? Protect the innocent. The actual goal? Police sexuality, women’s independence, art, and foreign voices (Joyce was Irish). The Comstock Act — which criminalized mailing “obscene matter” — gave Sumner the legal hammer. Cultural anxiety provided the motivation.
The 2025 Version: “Uncle Bobby’s Wedding”
If you think that rhetoric died in 1921, Justice Alito would like a word.
In June 2025, the Supreme Court ruled 6–3 in Mahmoud v. Taylor that Maryland parents have a religious right to withdraw their children from classes where LGBTQ-themed storybooks are discussed. Justice Alito’s majority opinion closely analyzed books like Uncle Bobby’s Wedding — a gentle picture book about a girl whose favorite uncle marries his boyfriend — reproducing color images in an appendix and noting they were written for young readers.
As Slate’s Mark Joseph Stern reported during oral arguments the conservative justices voiced concern — and at times, outright disgust — toward books for portraying LGBTQ+ people as normal and loving. Alito suggested the books were “devious propaganda aimed at indoctrinating children.”
Swap Joyce for Uncle Bobby’s Wedding. Swap modernist literature for LGBTQ-themed picture books. Swap 1921 for 2025. The playbook hasn’t changed.
(For more on the Mahmoud v. Taylor case, and all things Supreme Court related, see Mark Joseph Stern’s crucial coverage in Slate and on the Amicus with Dahlia Lithwick podcast.)
Comstock’s Revenge: The Zombie Law Awakens
And it’s not just about books. Post-Dobbs, anti-abortion activists realized they could use the Comstock Act to ban the mailing of abortion medications and medical equipment nationwide, no congressional vote required.
During oral arguments in FDA v. Alliance for Hippocratic Medicine, Justices Alito and Thomas (the same justices leading the charge on book bans) raised questions about applying Comstock to abortion pills. Project 2025 explicitly outlines plans to revive it to restrict reproductive healthcare.
Jonathan Mitchell — the lawyer behind Texas’ abortion “bounty hunter” law — told The New York Times: “We don’t need a federal ban when we have Comstock on the books.”
A zombie law is being reanimated.
Guilty of Publishing Literature
Anderson and Heap were found guilty on February 21, 1921. They each forfeited $100 bail, and the court issued an injunction against the July-August 1920 issue. The judges acknowledged Joyce’s literary intention but concluded they couldn’t overlook the “indecent passages.”
Anderson saw it as partial victory — the court recognized literary intention. But Jane Heap cut to the heart: “They just proved that literature is indecent.”
When the Village Was Radical
Another highlight of the book is how Morgan shows us the world Anderson was fighting to protect.
“Margaret stepped out onto Fifth Avenue and saw Greenwich Village at the height of its golden age, its meandering cobblestone streets having given rise to a renaissance in art and literature.” — from Morgan’s chapter “The Free and Independent Republic of Greenwich Village”
Morgan’s courtroom details are precise — I know because Jefferson Market Courthouse is now my neighborhood library. I check out books where she was prosecuted for publishing one.
But the building is just one artifact of what Greenwich Village was: a radical hotbed of experimental art, sexual freedom, and political activism that thumbed its nose at respectable society. The Little Review had offices on 8th Street at 27 West 8th Street. There should be a plaque there.
This was the neighborhood where Emma Goldman preached anarchism and birth control, where artists and writers lived in cheap walk-ups and reinvented American culture, where being queer wasn’t just tolerated but celebrated.
Anderson’s life after the trial? France, Gurdjieff, affairs with singer Georgette Leblanc and Dorothy Caruso (Enrico’s widow), a lighthouse on the Riviera. Not exactly a quiet retirement.
Nothing Is Inevitable
I initially felt the subtitle — “Margaret C. Anderson, Book Bans, and the Fight to Modernize Literature” — was too grand promise. In fact, the publisher showed restraint. This is an ambitious, deeply researched study that keeps its strong narrative intact. Morgan masterfully weaves together boundary-pushing literature with a comprehensive historical backdrop: progressive politics, women’s suffrage, LGBTQ+ rights, birth control, and the dramatic Palmer Raids that sparked the founding of the ACLU through their resulting immigrant deportations.
But Morgan’s book is a warning: nothing is inevitable. The Comstock Act is back because we assumed it was safely dead and buried. It turns out we forgot to check for a pulse. The same justices eyeing it for abortion restrictions just ruled that LGBTQ-themed books are too dangerous for children. Margaret C. Anderson’s story reminds us that the fight for freedom of expression — and for women’s freedom, period — is never finished.
The Fine Print. Thanks to Atria/One Signal Publishers for the advanced galley.