Massachusetts, 383 U.S. 413, the court ruled that sex was "a great and mysterious motive force in human life", and that its expression in literature was protected by the First Amendment. By permitting the publication of Fanny Hill, the U.S. Supreme Court set the bar for any ban so high that Rembar himself called the 1966 decision "the end of obscenity". Only books primarily appealing to "prurient interest" could be banned. In a famous phrase, the court said that obscenity is "utterly without redeeming social importance"—meaning that a work with any redeeming social importance or literary merit was arguably not obscene, even if it contained isolated passages that could "deprave and corrupt" some readers. Nonfiction The court decisions that legalized the publication of Fanny Hill had an even more important effect: freed from fears of legal action, nonfiction works about sex and sexuality started to appear more often. These books were factual and in fact, educational, made available in mainstream bookstores and mail-order book clubs to a mainstream readership, and their authors were guests on late-night talk shows. Earlier books such as What Every Girl Should Know (Margaret Sanger, 1920) and A Marriage Manual (Hannah and Abraham Stone, 1939) had broken the silence and, by the 1950s, in the United States, it had become rare for women to go into their wedding nights not knowing what to expect. The open discussion of sex as pleasure, and descriptions of sexual practices and techniques, was revolutionary. There were practices that some had heard of, but many adults did not know if they were realities or fantasies found only in pornographic books. The Kinsey report revealed that these practices were, at the very least, surprisingly frequent. These other books asserted, in the words of a 1980 book by Dr. Irene Kassorla, that Nice Girls Do – And Now You Can Too. In 1962, Helen Gurley Brown published Sex and the Single Girl: The Unmarried Woman's Guide to Men, Careers, the Apartment, Diet, Fashion, Money and Men. In 1969 Joan Garrity, identifying herself only as "J.", published The Way to Become the Sensuous Woman, with information on exercises to improve the dexterity of one's tongue and how to have anal sex. The same year saw the appearance of Dr. David Reuben's book Everything You Always Wanted to Know About Sex* (*But Were Afraid to Ask). Despite the dignity of Reuben's medical credentials, this book