Deep Throat gets a pass, but Caligula is "obscene"

Being from Boston, I recall the hoopla in Boston when this was released. So, what gives: Deep Throat was OK, as long as it didn't play at the nice theaters? Such B.S.

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In Boston, Massachusetts, authorities seized the film. Penthouse took legal action, partly because Bob Guccione thought the legal challenges and moral controversies would provide "the kind of [marketing] coverage money can never buy". Penthouse won the case when a Boston municipal court ruled that the film had passed the Miller test and was not obscene. While the Boston judge said the film "lacked artistic and scientific value" because of its depiction of sex and considered it to "[appeal] to prurient interests", he said the film's depiction of ancient Rome contained political values which enabled it to pass the Miller test in its depiction of corruption in ancient Rome, which dramatized the political theme that "absolute power corrupts absolutely".