Lenny Bruce (1925–1966) was arrested on obscenity charges after performing at a San Francisco club on October 4, 1961. During the trial, Bruce’s lawyer invoked the tradition of Chaucer and James Joyce, arguing that Bruce employed satire to criticize a hypocritical society. Although the jury found Bruce not guilty, he subsequently faced similar prosecutions in Los Angeles, Chicago, and New York, and died of a drug overdose while waiting for the appeal of a jail sentence.