Aren't We Guilty Too?: The Censorship of D.H. Lawrence in the Ivory Tower
Erin K. Johns Speese
 Traveling to the Modernist Studies Association conference last year, I was seated on a plane next to a tenured professor. As a Ph.D. candidate, I was asked that most dreaded of questions: "So what are you writing about in your dissertation?" Briefly, I delivered my elevator ride length blurb. In response, I was asked my second most dreaded question: "If you're writing on gender, what authors are you focusing on in your dissertation?" I dread this question because even though I explore issues of gender, my project focuses on reconsidering male writers in terms of representations of both masculinity and femininity. And, when I get to the part about how my project includes D.H. Lawrence, I brace myself for the response I have already gotten many times: "D.H. Lawrence. The misogynist?" My response is always the same: "Yes. That's the one." Then, in a condemning tone, my seatmate responded: "Why? He's a fucking asshole." How on earth do I respond to that? From an established professor in the field of modernism, I would have at least expected a more nuanced response as to why exactly Lawrence is an "asshole" rather than a declaration. I include this episode because I have had many like it in response to my work on Lawrence. I had to convince my dissertation advisor to reconsider him from a new viewpoint. In our English department, Lawrence is a small short story or a poem in an otherwise packed British survey course—if he makes an appearance at all.  In contrast, Rachel Bowlby notes that the 1972 Oxford Anthology of English Literature included Lawrence's auxiliary publications like "Pornography and Obscenity," which indicated that even they were canonical (113). In the recent, standard British anthologies, the Norton and the Longman, Lawrence's poetry and short stories are included; however, the selected pieces reveal a "safe" Lawrence and often do not contain his sexualized language that feminist critics challenged. Lawrence is still a part of the canon, but he has been sanitized.  This change reflects a shift in attitude toward Lawrence in the past forty years. As both Gary Adelman and Sandra Gilbert confirm, there is a need to "reclaim Lawrence"; however, as a variation on what Mark Twain most famously said, the reports of his literary death have been greatly exaggerated. 
 Perhaps more than anything, Lawrence is known as an obscene writer who challenged social norms with his detailed representation of sex and impotence in Lady Chatterley's Lover. For those who do not engage in formal study of his work, Lawrence is the ultimate rebel, challenging prudish Victorian ideals by espousing less rigid sexual roles for men and women. Critical readings of Lawrence, especially in terms of gender and sexuality since Kate Millett's denouncement of him in the 1970s, make him out to be the ultimate bad boy—not in the sexy but in the patriarchal sense. Ironically, academics that specialize in literature are typically anti-censorship, focusing on the importance of understanding the written or spoken word rather than deleting it. However, despite his initial canonization in modernism, Lawrence has become a figure deleted—the whipping boy, the ultimate example of misogyny and racism. I argue that we need to reconsider how not only the legal system but also the academy have both succeeded and failed at censoring Lawrence. Examining the involvement of literary critics detailed in the Trial of Lady Chatterley transcripts and Kate Millett's aggressive feminist response to Lawrence, I recontextualize Lawrence by taking into account how we too, as academics, like legal and social systems, have censored Lawrence from a perspective reflective of our cultural and critical ideologies.
 In Britain, the Obscene Publications Act of 1959 is important to academic criticism for two major reasons: 1) that a work is not considered obscene if it is "for the public good on the ground that it is in the interests of science, literature, art, or learning" ("OPA 1959" 4) and 2) that the "opinion of experts as to the literary, artistic, scientific, or other merits may be admitted...either to establish or to negative the said ground" ("OPA 1959" 4). In other words, to combat obscenity, the critic must play the role of the censor by determining what does or does not have artistic merit. As Jonathan Dollimore has pointed out, the intellectual that "take[s] art seriously" is also invested in controlling it by suggesting that the critic's "conviction that true art should not of its very nature be subject to censorship, actually produces a censorship of its own" (97). In 1961, Lady Chatterley's Lover was chosen as the first text to be tried under the Obscene Publications Act of 1959 even though it was initially published in 1928. Why would a text already thirty years old be the test case for a trial in 1961? A major change in the academy during this time span was the development of modern literary criticism as a result of an emphasis on canonization that validated the institutionalization of English as a discipline of study. In essence, what is put on trial in 1961 is not Lawrence's obscenity but the process of canonization by which Lawrence became a major early twentieth century figure. What was at stake was the validity of academic criticism and the intellectual elite.
 When I imply that critics act as censors, I want to stress some of the issues surrounding literary studies that have come to emphasize theory over the value of close reading, especially through the review of a large portion of an author's oeuvre. As a result, blanket statements about the functions of power have dominated the discourse of literary studies as more critics have turned to cultural studies. Both critics and teachers come to dictate what texts should be read, and with the rise of theory, how those texts should be read. The rise of the literary critic during the Lady Chatterley trial on censorship made possible the powerful impact of theory on the literary establishment. The trial not only showcases that literary critics hold sway over whether or not a text should be read, but more importantly, how a text is read. With this move, critics remain the ultimate purveyors of "taste" and reveal changing social attitudes of their time. In the context of the Lady Chatterley trial, the critic reflects the social movement of the 1960s toward a more free expression of sexuality. Similarly, the rise of poststructuralist criticism in the 1970s reveals the deconstruction of power systems, ideology, and identity categories. In essence, what was acceptable about Lawrence's work as it parallels the sexual revolution during the Lady Chatterley trial becomes unacceptable as literary studies moves toward more specific readings of power structures that create subjectivity and ideas of identity. The move toward poststructuralism in the 1970s made it no longer acceptable to read Lawrence in the same way.
 By tracing the importance of the Lady Chatterley trial to the establishment of the literary critic and also following critical responses to Lawrence as a result of poststructuralist criticism, a narrative emerges about the value of the critic and how his/her role as arbiter of "taste" has transformed over the past fifty years. Although taste implies value, what this history reveals is that critics as well as teachers function as censors in an inconspicuous and nuanced way. Now more than ever, with the reliance on university- or college-level education for jobs, more people come into contact with the literary critic than ever before. Even if this includes only those students who major in a humanities field or literary studies specifically, the increase in enrollment means an increase in those who are exposed to the literary critic. Teachers (who are often literary critics via their research) who select some texts for a course are constantly excluding others. John Guillory explains that the debate over the canon reveals three basic tenants related to critical estimations of works of literature: 1) "Canonical texts are the repositories of cultural values" (22), 2) "The selection of texts is the selection of values" (23), and 3) "Value must be either intrinsic or extrinsic to the work" (26). What Guillory traces is the exclusion of some voices in favor of others reveals a particular set of values that is synonymous with the academy. The rise of poststructuralist criticism, especially by feminists who sought the inclusion of female voices in the canon, shows that the dominant narrative of the canon has been one of exclusion and (might I say) censorship. More than anything, this move shows that there might be problems with our "taste" in literature.
 Traditionally, censorship is associated with a state or government move to suppress information. By defining the critic as a form of censor, I follow the metaphorical move made by Pierre Bourdieu; he suggests, "The specialized languages that schools of specialists produce and reproduce through the systematic alteration of the common language are, as with all discourses, the product of a compromise between an expressive interest and a censorship constituted by the very structure of the field in which the discourse is produced and circulates" (137, emphasis original). Although he is invested in analyzing the interplay between signifier and signified in the philosophy of Heidegger, Bourdieu's observations about the function of the language of philosophy and its interaction with the academy apply in similar terms toward the literary critic. He points specifically to the use of specialized languages that employ a common word but infuse it with a philosophical meaning. In this act, the philosopher engages in censorship. Bourdieu goes on to comment on the importance of the field of study in imposing form: "The metaphor of censorship should not mislead: it is the structure of the field which governs expression by governing both access to expression and the form of expression, and not some legal proceeding which has been specially adapted to designate and repress the transgression of a kind of linguistic code" (138). Bourdieu implies that it is the use of discourse and not the formal legal proceedings of censorship that actually censor. It is not the actual language but the meaning that becomes the crux of the problem of censorship—both metaphorically and legally. In the Lady Chatterley trial, the tension between meaning and the word are revealed through the testimony of a number of literary critics. Formally, the legal proceeding attacks Lady Chatterley's Lover on the basis of specific words while the critic draws attention to the misrepresentation between the word and the meaning as intended by Lawrence.
 Like traditional censorship which relies on a governing body to dictate what can and cannot be said, the academy wields discourse in such a way that allows members to function as an institutionalized body that dictates appropriate language or a specific level of taste. Judith Butler examines what she terms "implicit censorship" or the "powerful operations of censorship that are not based in explicit state policy or regulation" (249). Butler then argues that there is a more threatening middle ground between explicit and implicit censorship where "ambiguous forms of censorship may be more efficacious than explicit forms in rendering certain kinds of speech unspeakable" (250). When applied to the function of the academy as relates to poststructuralist criticism, there is an ambiguous mechanism at work, which reveals what types of writing rather than speech are unspeakable. I see the critic as existing in this ambiguous middle ground and who implicitly wields censorship by interpreting the meaning of literary texts in a particular way. The academy represents a dominant power structure that indicates what should and should not be read, what is and is not published, and what authors we should and should not like; it operates under a particular view of literary studies that excludes other voices, including those that do not want to participate in its "elitism" or those who may want to embrace authors (like Lawrence) that current discourses suggests they should not. The critic can function as part of a body that censors through his or her ability to dictate standards of taste. In his introduction to the PMLA special issue on censorship, Michael Holquist points out this paradox: "[Censorship's] authority can never be separated from a need to include" (14). Although I say that critics act as censors, I do not want to suggest that the critic is unimportant. Instead, I would like for critics to be more aware of their own paradoxical position. As Holquist also suggests, "[C]ensors too are always censored. Together with their victims they are constrained by what is possible amid social forces whose lines of influence bound—while extending beyond—the ecosystem in which censorship seeks to exercise discursive hegemony" (17). When applied here, the literary critic is subject to his or her environment—the way she or he was educated in the subject, how that education is linked to the environment of the academy, and what the academy has already deemed acceptable for literary discourse.  Of course, there is no real way out of this double bind; however, critics should constantly consider the history of inclusion and exclusion in academic discourse.
 Perhaps more than any other censorship trial before its time, the Lady Chatterley trial relied on the evaluations of many cultural critics in order for Penguin Books to escape the charge of publishing obscene material in the form of Lawrence's novel Lady Chatterley's Lover.  By the 1970s, feminist critics would use theory to place the canon on trial as well, but their focus would be on recuperating female writers whereas the Lady Chatterley trial focused on validating the obscene and pornographic work of a writer lauded as a major figure in the modernist British canon.  Yet both feminism and obscenity trials have something in common. They both ask the question: What counts as literature and why? It is a question that stems from F.R. Leavis's emphasis on canonization as an endorsement of high culture resulting in a process that noted the importance of the literary critic in determining literary status. For Lawrence in particular, Leavis advocated for his position in the "great tradition" of the British novel. Ironically, this same process would play out again as feminist theory developed its own canon and as Lawrence's most publicized feminist critic, Kate Millett, fell into a similar position within her own canon. What both of those histories reveal is a pattern of exclusion or inclusion that relies on the voice of the critic and the ideology of the academy (even if it constantly changes over time).
 In terms of the Lady Chatterley trial, the key question examined by the defense against the charge of obscenity was whether or not Lawrence's work had any literary merit. In his closing remarks, Gerald Gardner (of the defense) suggests that literary merit is not static and must evolve with changing social dynamics; he says, "When one is considering whether this [obscenity] has the tendency to deprave and corrupt one cannot divorce the question altogether from the climate of literature, in the sense that times change" (Rolph 203, my emphasis). The defense made the trial not about whether or not Lady Chatterley's Lover was obscene, but whether or not it was literary. If the text held literary merit, then, it could not be deemed obscene. As a result, the defense paraded out a number of critics and literary reviews or criticism in order to make their case. Sean Matthews has extensively detailed this use of critical material as an "odd collision of the British Common Law with academic literary criticism" (170). Matthews's focus, though, is on how "class, criticism, and culture" (170) intersect rather than on the specifically gendered implications of Lawrence's work in the academy. Matthews connects the Lady Chatterley trial to the validation of literary and, eventually, cultural studies.
 Drawing on Matthews's assertion, the critical dynamics of the trial eventually established the critic as validator of cultural and literary capital; however, when counter-examined from the opposite side, the critic was also endowed with the role of cultural and literary censor. In deeming whether a text has merit, the literary critic uses predetermined standards to both deny and support censorship throughout the Lady Chatterley trial. Gerald Gardiner first set up the terms of the debate that would be reexamined by literary critics in his opening address. His strategy was to remove the cultural view of sex as "disgusting and sinful and unclean" (Rolph 30) in favor of a more spiritual representation of sex by Lawrence. To that end, Gardiner refers to Lawrence as a "puritan moralist" as "he plainly disapproves of casual sex, of sex without love, of promiscuous sex; but he strongly approved of, and thought that our society as a whole paid too little attention to, the physical love of a man and woman in love and in a permanent relationship with one another, which, in his view, plainly was healthy, wholesome, normal, and to be encouraged" (Rolph 30). The main strategy of the defense was to introduce Lawrence as more true to the ideals of marriage and Christianity than his use of "four letter words" would suggest. Since the basis of obscenity trials is morality, the defense creatively invokes the term in order to redefine it related to a commitment to truth. For Lawrence, this commitment is intimately linked to sexuality, and as a result, it gives literary critics a platform to implicitly critique social structures like marriage in order to address a rapidly changing social order.
 The use of terms like "moral" and "Puritan" were employed by the defense and redefined by literary critics and reviewers in support of Lawrence's novel. The defense relied on the testimony of writers like E.M. Forster who deemed Lawrence a moral or Puritan writer by comparison to John Bunyan: "They were both preachers. They both believed intensely in what they preached....Lawrence too had this passionate opinion of the world and what it ought to be, but is not" (Rolph 113). Forster's ironic comment equated Lawrence with a preacher, a person who typically condemned obscenity on moral grounds. When he was asked about the merits of Lawrence's novel, literary critic Richard Hoggart also relied on the concept of "puritanism": "In England today and for a long time the word 'puritanical' has been extended to mean somebody who is against anything which is pleasurable, particularly sex. The proper meaning of it, to a literary man...is somebody who belongs to the tradition of British puritanism generally...an intense sense of responsibility for one's conscience" (Rolph 99-100). Lawrence's work is validated for his commitment to a particular idea, even if that idea found representation through sexual intercourse. Both Forster and Hoggart point to how Lawrence's work (despite its sexual content) has larger social and humanist concerns as its focus.
 By ironizing the term "puritanical," Forster and Hoggart implied a distinction between the intellectual elite and the common reader. Even though he claimed that Lawrence's text transcends intellectual classes by suggesting that "any good reading of the book, I don't mean a highbrow's reading, a good decent person's reading of the book, shows there is no one [sex scene] the same as the next; each one is a progression of greater honesty and greater understanding" (Rolph 95). Hoggart undermined his own simple reading of the book's "honesty" by engaging in an intellectual validation of the text through the concept of "puritanism." Since the crux of the Lady Chatterley trial is censorship, Hoggart is placed in a double bind. He must refute efforts by the legal system to censor Lawrence's text but maintain his role as cultural critic or censor, thereby both underplaying and showcasing his intellectual superiority. While championing anti-censorship, the literary critic uses his superior academic position to censor the intellectually inferior. If Lawrence is not obscene due to his commitment to his ideals and his "puritanism," Hoggart and Forster implicitly suggest that writers who do not show this commitment merit censorship, because their work does not contain literary merit. Ultimately, "sex" in Lawrence is superior to "sex" as understood by the masses.
 The reason that Forster and Hoggart are able to reify their positions as critics is due to the prosecution's emphasis on a difference between the lay reader and the intellectual elite that made up much of the defense's evidence. The prosecution claimed to champion the moral purity of the common person by repeatedly making reference to whether or not the text has the tendency to "deprave and corrupt" (Rolph 16)—especially adolescents. Griffith-Jones addresses this directly in his opening. He asks the jurors to consider these questions: "[W]ould you approve of your young sons, young daughters—because girls can read as well as boys—reading this book. Is it a book that you would have lying around in your own house? Is it a book that you would even wish your wife or your servants to read?" (Rolph 17). This line of questioning suggests that the ordinary reader would find no value in this book and would be concerned about its ability to corrupt children and especially wives.
 The defense confronts the prosecution's emphasis on the common reader with the testimony of many literary critics. In the closing address, Gerald Gardiner directly confronts the prosecution's attempts to discredit intellectual opinions because they do not represent the common reader. Gardiner advises the jurors that
It is very easy to adopt the line, "You and I are ordinary chaps, and don't you bother about these experts, because they are teachers who live in their books and they don't really know what goes on in the world: you have seen them in the witness box, they don't do shopping and washing up and get married and have children, they don't really know what goes on at all." (Rolph 198).
Gardiner shows how the prosecution tried to discredit the intellectual elite because they do not represent the reading ability and opinion of "ordinary chaps." Gardiner cleverly plays on the cultural stereotypes about intellectual elites in order to appeal to the jury; however, he also makes it clear that the opinion of these "experts" is important to determining whether or not the text has any literary merit.
 In addition to redefining "moral puritan" and addressing the issue of the common reader, the trial also emphasizes the novel's representation of marriage as its key social threat. The interpretation of marriage by critics during the Lady Chatterley trial suggests that Lawrence consistently critiqued marriage as a social institution that imposes particular social norms. In many ways, the critics suggest that Lawrence is engaged in critiquing marriage in a similar manner to current queer theorists. For instance, Valerie Lehr reveal that the state is always already implicated in the construction of family: "The family, according to the dominant ideology, is a realm in which we build permanent and caring relations, rather than fleeting and competitive relations....Yet the state—which has the power to set the terms for marriage contracts, for child custody, and for privacy—is never outside of the family" (19-20). Lawrence reverses the traditional paradigm by associating the caring relationship with Connie's affair while "competitive relations" are revealed in her traditional marriage to Clifford. Lisa Duggan insists that "we must contest romanticized notions of privacy and family as outside capitalist relations of exploitation and domination or—as generations of feminist scholarship has taught us—as free of gendered labor and value" (8). Connie's dissatisfaction with her role as wife to Clifford, an aristocratic if not an expressly capitalist exploiter, shows how she fails to conform to the gendered labor structure expected in the private sphere.
 Michael Warner in articulating an "ethics of shame" suggests that the normalizing influence of heterosexuality is not the normal to which queer people should aspire:
[H]eterosexuality might be irrelevant to the normative organization of the world. People are constantly encouraged to believe that heterosexual desire, dating, marriage, reproduction, childbearing, and home life are not only valuable to themselves, but the bedrock on which every other value in the world rests....Nonstandard sex has none of this normative richness, this built-in sense of connection to the meaningful life, the community of the human, the future of the world. It lacks resonance with the values of public politics, mass entertainment, and mythic narrative. (47)
As the critics at the trial show, Lady Chatterley's Lover reveals what Warner terms the "normative organization of the world" through marriage as a faulty assumption on behalf of the prosecution. By revealing Lawrence's idea of marriage as different from traditional marriage, the critics at the trial reveal Lawrence as a figure who wants to rethink the confines of heteronormative structures that institutionalize marriage. 
 State and legal systems preserve marriage as it validates patriarchal and heteronormative family units, and the Lady Chatterley trial makes this investment obvious. As the trial proceeded, it became clear that the selection of Lawrence's novel for the obscenity trial has more to do with how it disrupts the "moral" systems associated with patriarchal family and class structures rather than with the actual language itself. In terms of sexuality, the bulk of the trial was spent justifying Lawrence's representation of sexuality related to traditional marriage or in revealing the egregious error of Connie Chatterley's adulterous affair with the low-class Mellors, the gamekeeper. In both cases, Lawrence's novel is obscene because it conflicts with traditional social structures and discourses that value monogamous, heterosexual relationships validated by the church. The critics from the trial show that Lawrence's idea of a true marriage is represented in the adulterous relationship between Connie and Mellors rather than the legitimate marriage between Connie and Clifford. Lawrence discredits the institutionally endorsed marriage between Connie and Clifford. Although his paradigm is still heteronormative, Lawrence reveals the tension between sexual desire and marriage as an institution. Like the argument of many current queer theorists, Lawrence points to the failure of marriage as an institution which is invested in maintaining certain class boundaries that reify Clifford and denigrate Mellors. This was further emphasized in the trial itself as the prosecution attacked the adultery in the text as an attack on traditional marriage.
 As the trial continued, the focus becomes less on the frequency of sexual acts or the descriptive "four letter words" used to describe those acts and more on how sex in the novel devalues traditional marriage. In overviewing the plot of the novel, Griffiths-Jones begins by describing Connie as morally corrupting marriage with her sexuality: "[T]he book is a book describing how that woman, deprived of sex from her husband, satisfies her sexual desires—a sex-starved girl—how she satisfies that starvation with a particularly sensual man who happens to be her husband's gamekeeper" (Rolph 18). Although after the overview he goes on to discuss the language used in the novel and the number (thirteen) of sex scenes between Connie and Mellors, Griffith-Jones's framing of the story around the overly sexualized image of Connie Chatterley as an adulterous woman reveals that the more important issue is how the novel corrupts the sanctity of marriage. In order to combat this interpretation of marriage in the novel, Gerald Gardiner (of the defense) claims that Lawrence "is clearly a very strong supporter of marriage.... It is quite plain, in my submission, from the whole of this book that the author is pointing out the promiscuity yields no satisfaction to anyone and that the only right relationship is one between two people in love which is intended to be a permanent one" (Rolph 29). Lawrence's commitment to this higher truth is what makes him a "moral puritan" as it presents a more true and honest interpretation of love and marriage. In addition, Lawrence "thought we paid much too much attention to the mind and not nearly enough to the body; that the ills from which society was suffering were not going to be cured by political action; and that the remedy lay in the restoration of right relations between human beings, and particularly in unions between men and women" (Rolph 29). Lawrence's text is threatening because it reveals the physical body rather than lofty ideals surrounding "love." Lawrence refutes political systems in favor of personal systems that disregard the hierarchies validated by the church and law (like marriage). Lawrence's novel is obscene because it reveals that a sexual-spiritual union is needed in order to combat the intellectualism of the twentieth century. Ironically, it is those of the "mind," the intellectuals that validate Lawrence's reinterpretation of marriage.
 Many critics who testify on behalf of Lady Chatterley's Lover discuss Lawrence's views on marriage and the body as revealed in the novel. They attest that the carnal sexuality depicted between Mellors and Connie is necessary to understanding Lawrence's critique of marriage. Graham Hough says that the sexual scenes "show the development of Connie Chatterley's awareness of her own nature" (Rolph 44). Joan Bennett claims that the novel "does not say very much about his view about the law concerning marriage, but it does make clear that a union between two persons who love one another is of great importance" (Rolph 63). During cross-examination, it becomes clear that the legal discourse employed by both the prosecution and the defense does not align with the discourse used by literary scholars and reviewers. In questioning Bennett on the novel, Griffiths-Jones constantly attempts to undermine her perspective by employing the legal rather than spiritual idea of marriage. In her response, Bennett shows that there is a clear distinction between marriage as understood by the court and marriage as represented by Lawrence in the novel. The trial continually reveals the slipperiness of language and how the concise, "scientific" language of legal discourse cannot easily be applied to literature. As a result, the critic becomes the necessary translator who provides the "facts" that must be conveyed to the average person or the juror.
 As in the obscenity trial, "sex" becomes the key term in Kate Millett's critique of Lawrence's work. Drawing on feminist activism, Millett's work reconsiders canonical male writers in terms of their "sexual politics," which becomes the title of this now foundational feminist text. Millett's critique of patriarchy related to sexuality became the method of feminist literary critics from the 1970s to the present. Recent literary scholarship on gender and sexuality in Lawrence often cite Millett as the fountainhead from which the idea of the misogynist Lawrence springs. Peter Middleton suggests that Millett is responsible for the fact that "Lawrence's status as a significant modernist writer has fallen a long way" (68). David Seelow writes, "D.H. Lawrence, for example, has been pillaged ever since the publication of Kate Millett's Sexual Politics in the late 1960s" (130). Gary Adelman remarks that for the academe, "the prevalent view of Lawrence is Kate Millett's (1970), that he [Lawrence] is merely a sexual politician who 'goes to every length to make the lot of the independent woman repellent'" (75). And, not only Lawrence scholars but also feminist scholars see Millett as a problematic figure. The most vociferous outcry against Millett comes from Camille Paglia, who lists Millett's many sins, including "tunnel vision," a "lack of hard political knowledge," and "a shrill reductiveness" of discourse (112). Ironically, Paglia's feminism also has many of the same problems as Millett's, but her tone aligns with that of many Lawrence scholars. Notice the overwhelmingly negative tone of these citations of Millett. As in the Lady Chatterley trial, literary critics not only determine who is or is not worthy of censorship but whose critical or scholarly work is valid in discussions of Lawrence and even feminism.
 In many ways, Millett is responsible for the amount of feminist scholarship that reads Lawrence as "misogynist," but we also have to consider how the critical terminology from the Lady Chatterley trial influenced Millett's reading of his "sexual politics." Like the critics at the Lady Chatterley trial, Millett sees Lawrence as a preacher and even a puritan, although not in the same form. Critics like Hoggart establish Lawrence as a preacher, highly invested in his own sexual politics. Millett picks up on this critical tradition, but rather than using that idea to validate Lawrence's place in the canon, she undermines not only Lawrence but also the misogyny of the academy. Millett reverses the admiring tone of Hoggart and Forster and regards Lawrence's preaching, which she terms his "personal cult, 'the mystery of the phallus'" (238). More importantly, the issue of the "phallus" is brought to the forefront in the Lady Chatterley trial as a key term that needs exploration. In presenting witnesses for the defense, many of the literary critics interpret the "phallus" as part of Lawrence's philosophy related to sexuality. In recounting the critical responses listed on the cover of the new Penguin edition of Lady Chatterley's Lover, Griffiths-Jones draws attention to one particular remark: "This story of the love between a gamekeeper and the wife of a crippled intellectual is therefore one of 'phallic tenderness'" (Rolph 20). Then, in a brief aside, Griffith-Jones comments, "Members of the Jury, for those of you who have forgotten your Greek, 'phallus' means the image of the man's penis" (Rolph 20). In his closing address, Griffith-Jones strictly reads Lawrence's use of "phallus" as completely interchangeable with the word "penis": "Perhaps it will not have escaped you what Mr. Gardiner had invited you to remember, that 'phallic' is a holy word, a religious word, always used in connexion with holiness. Read it, and see whether it is used in that sense here" (Rolph 223). At which point, he goes on to quote a "purple passage" from the text that uses the "phallus" in a purely sexual context. In fact, although a negative reading of Lawrence, Millett engages in a larger critique of the term "phallus," which pulls away from Griffith-Jones's insistence on its simple equation with the "penis." Ironically, Millett actually explores the term beyond its merely sexual connotation in a way that reveals its religious origins as Gardiner asserts; however, what she finds actually problematizes rather than endorses Lawrence. In exploring the term in the way literary critics throughout the trial insist, Millett points to a larger social context rather than a strict emphasis on language.
 Kate Millet's exploration of the "phallus" is more strongly linked to its ideological function, especially in terms of patriarchy. Like Gerald Gardiner, she too returns to ancient society to define the terms, but in this case, she reveals a cultural context: "There is some evidence that fertility cults in ancient society at some point took a turn toward patriarchy, displacing and downgrading the female function in procreation and attributing the power of life to the phallus alone" (Millett 28). Immediately following this brief discussion of the phallus, Millett exposes the religious link that Gardiner emphasizes in order to reveal the patriarchal connotations: "Patriarchal religion could consolidate this position by the creation of a male God or gods, demoting, discrediting, or eliminating goddesses and constructing a theology whose basic postulates are male supremacist, and one of whose central functions is to uphold and validate the patriarchal structure" (28). From this historical analysis, Millett can then proceed to explore Lawrence's use of the term "phallus" as part of a religious but, more importantly, patriarchal tradition. By drawing on this key term from the Lady Chatterley trail and examining it in the way that the defense advocates, Millett follows through on the analysis that is emphasized by the literary critics who spoke in support of Lawrence.
 Millet's chapters exploring the history of patriarchy and the phallus delve into the historical dimensions of the ideologically loaded terms; however, when she explores these terms in her reading of Lawrence, the problems of language and terminology that emerged during the trial reemerge in her text. Despite her initial exploration of the cultural and historical context for the term "phallus," when analyzing Lawrence, Millett suddenly begins to read the term as simply a substitute for the "penis": "In Lady Chatterley, as throughout his final period, Lawrence uses the words 'sexual' and 'phallic' interchangeably, so that the celebration of sexual passion for which the book is so renowned is largely a celebration of the penis of Oliver Mellors, gamekeeper and social prophet" (238). This shift from an in-depth exploration of the historical context to the more simplified reading of the "phallus" as "penis" is perhaps why so many Lawrence scholars have reacted so negatively to Millett's work. In fact, Millett tries to rectify the historical and religious history of the phallus with its more pejorative meaning. She rightly links this to a patriarchal tradition, and her text more actively engages in trying to account for the slippery nature of the term "phallus" itself—a slipperiness that is a rhetorical tool in the arguments of both the prosecutor and the defense during the Lady Chatterley trial.
 Considering the religious history of the term "phallus," the description of Lawrence as a "moral puritanist" or "preacher" becomes more valid as he is tied to the religious or sacred interpretations of the term. According to Millett, Lawrence uses "sexual" and "phallic" interchangeably, which allows her to later term Lawrence as an evangelist rather than a puritan: "While insisting his mission is the noble and necessary task of freeing sexual behavior of perverse inhibition, purging the fiction which describes it of prurient or prudish euphemism, Lawrence is really the evangelist of quite another cause—'phallic consciousness'" (238). Later, Millett also draws in the term "puritan" in discussing the queer politics of Lawrence's inclusion of the Birkin/Gerald wrestling scene in Women in Love: "Held back by his own puritan reluctance in such matters he feels safer in flirting, since to his discretion, there is a strong danger of being branded effeminate. As a result, there is always something prurient about the homosexual strain in Lawrence" (267). In her analysis of Lawrence, Millett employs the term "puritan" from the Lady Chatterley trial, but she does not see the term as a progressive statement on Lawrence's work. Instead, Lawrence's puritanism inhibits queer sexuality, and her usage of the term "puritan" subverts the critical terminology set forth in the Lady Chatterley trial.
 In detailing feminist responses to Lawrence, Carol Siegel traces a number of critics who also criticize Lawrence in a similar way as Millett, including Annis Pratt, Mary Jacobus, Sandra Gilbert, Susan Gubar, and Eve Sedgwick. These critics became the foundational voices of feminist criticism; however, their approach reveals the influence of French poststructuralist feminist criticism that focused on essentialism as the grounds for their feminism (even if it was "strategic").  As Siegel so aptly deduces, "It seems to me necessary for feminist criticism to concentrate on gender differences, but it is unnecessary for us to simplify them by creating allegorical figures to embody them. We should look as skeptically at feminist descriptions of Lawrence that reduce him to a symbolic Other as we do at patriarchal reductions of women writers" (6). What Siegel implicitly suggests is that identity based politics that result from poststructuralist theory and criticism often reduce complicated issues and texts into binary thinking. There is of course no easier way to make a point than by emphasizing a particular figure (or in this case author) as exemplifying all that is the worst of that issue (in this case patriarchy). Siegel correctly points to the irony that when women's literature is discussed, Lawrence's work reflects a long conversation (even if conflicting and perhaps patriarchal) with women's rights, especially as regards sexuality and marriage. Millett is right to point out that Lawrence's most insidious tool in Lady Chatterley's Lover is to present patriarchal ideology from Connie's perspective, but it might also explain why Lawrence is so often tied to women's literature. His texts appeal to women as they try to reveal the complicated relationship a woman has with patriarchal society—as sometimes an endorser (whether intentionally or unintentionally) or as an oppressed subject to its power. The contradictory voice of Lawrence reveals the contradictory nature of female subjectivity under patriarchy.
 The post-Millett feminist responses to Lawrence construct him as a representative figure of patriarchy, but much like essentialism, this was perhaps a strategic move. As a result of the Lady Chatterley trial, Lady Chatterley's Lover circulated more widely as an obscene text. In the decade directly preceding Millett's publication of Sexual Politics, two important events occurred: 1) the recirculation of Lady Chatterley's Lover as an uncensored text (thanks to the voices of the critics in the trial) and 2) the claiming of Lawrence by aggressively sexist authors like Henry Miller and Norman Mailer (Siegel 5). No doubt, the Lady Chatterley trial is the event that connects Lawrence to Miller and Mailer, because Lawrence's representation of sexuality is not considered obscene and makes sexuality literary (as the critics prove). It then seems reasonable that Millett would further link the relationship between the authors in Sexual Politics; however, by seeing Lawrence as a precursor, Millett over-simplifies her reading of his texts. In this same way, many feminist critics are both attracted to and repulsed by Lawrence's work.
 Despite a fair amount of attempts to reconsider Lawrence's work in the academy, the main narrative of Lawrence is that of the antifeminist, misogynist, and patriarchal figure. By making Lawrence an allegorical figure as Siegel suggests, the image has become more important than the man. Critics can dismiss considering Lawrence's work at all, because he is the fountain from which all twentieth century patriarchal literature springs (or so the narrative goes). In contrast, a number of scholars have argued on behalf of a more nuanced reading of Lawrence. Stephen P. Clifford writes that in Lawrence
[C]onstructs of masculinity that have been set up as straw men, and if we are paying close attention, these constructs tend to deconstruct...As readers who see the merely sexual and the frequent attempts at domination by male characters, we are often mislead into constructing critical narratives of masculinity ourselves, and placing them into the texts as fixed ideological positions to either extol or disparage. (50-51, emphasis original)nity reveal dissatisfaction with traditional expectations involving gender roles. Linda Ruth Williams traces the distinction in Lawrence between "sex in the head" versus bodily sexuality; she writes, "The conflict between affirmation and denial of femininity, writing and the visual, is that which animates Lawrence's text" (9). Williams reveals Lawrence's emphasis on the importance of bodily experience over the idea of reason or knowledge. Finally, as Anne E. Fernald articulates, there is a need to consider Lawrence's auxiliary works in tandem with his fictional works in order to better understand his gender politics. By looking at Fantasia of the Unconscious, one of Lawrence's psychoanalytic texts, with Women in Love, a novel, Fernald can "unlock the reasons behind Lawrence's ultimate rejection of the androgynous vision in The Rainbow and the equal partnership of Ursula and Birkin in Women in Love in favor of the starkly polarized gender roles of The Plumed Serpent and other late fiction" (185). All of these critics point to the fact that Lawrence's constructions of gender are far more complicated than is represented by the Lawrence-as-misogynist strain in the feminist canon. Despite all of this fruitful scholarship on gender in Lawrence, Millett is still the critic to which Lawrence scholars seem to return. Like Lawrence for feminist criticism, Millett has become an allegorical figure for Lawrence scholars who seek to reconsider his work in light of readings that simplify him as a misogynist.
 Considering Millett's reading of Lawrence as the beginning of a patriarchal, misogynist, and male supremacist strain of literature, it is ironic that the prosecutor of the Lady Chatterley trial actually draws attention to this novel due to its potential to disrupt patriarchal marriage, especially through adultery. In supporting Lawrence as committed to marriage, many of the literary critics draw attention to his statements in "Apropos of Lady Chatterley's Lover" where he (as Gerald Gardiner points out) links marriage to Christianity in a favorable manner. As Cynthia Lewiecki-Wilson has suggested about his view of marriage in this short tract, Lawrence actually subverts gendered marriage norms; she writes, "Marriage is not an institution but a relationship of exchange" (109) for Lawrence. Lewiecki-Wilson goes on to explore Lawrence's praise of the "'phallic' marriage" or "phallic consciousness": "In using this term I mean to point out that Lawrence seeks roughly the same goal as proponents of a 'feminine consciousness': to subvert and dismantle the present thought systems of dominance and control. Lawrence wants to revivify those aspects of consciousness that modern, Western life represses in men: a sensual, intuitive, nonrational living" (110, emphasis original). By the mid-1990s, about twenty-five years after Millett's publication, some feminist responses to Lawrence (as shown by Lewiecki-Wilson) reconsidered Lawrence's novels in relationship to his critical work like "Apropos of Lady Chatterley's Lover." In doing so, Lawrence is once again revealed as a subversive figure who does challenge patriarchal order. The same terms used in the Lady Chatterley trial and Millett's response reappear as the basis for reevaluating Lawrence. Without the foundational controversy regarding sexuality and marriage as revealed in the Lady Chatterley trial and Millett's feminist response that developed a historical and cultural reading of patriarchy, scholarship on Lady Chatterley's Lover would not have been able to reconcile Lawrence's critical writing and his fictional representations. Without these debates about Lawrence's work, such scholarship would not have been able to reveal the complicated nature between what Lawrence represents, what he says, and how historical and legal discourse influence our readings of his texts.
 The critics of Lawrence at the Lady Chatterley trial and Kate Millett have more in common than appears so at the surface; they both, as one of my students put it, show that Lawrence takes the "sexy out of sex." In order to validate Lady Chatterley's Lover as a work of art, the critics prove that Lawrence uses sex as a vehicle to show his commitment to his personal ideals and ideology. Recently, Alison Pease has shown that Lawrence's representations of sex play out the tensions of the embodied expectations of pornographic texts and the disembodied notions of aesthetic disinterestedness (1-2). Like the critics at the Lady Chatterley trial, Pease shows that Lawrence's work is not mere pornography. Ironically, so too, does Millett; she shows Lawrence's sexual mythology is in fact more threatening than mere pornography. Millett successfully proves that Lawrence's use of sex in Lady Chatterley's Lover reinforces his preaching; however, that sermon is one that ultimately troubles Lawrence's position as canonical in terms of post-1970s literary scholarship.
 Why does all this channeling of critical "he said/she said" matter? What, you may ask, does this have to do with Lawrence? As a result of Millett's critical work, Lawrence became for a time the whipping boy of some front-line strains of feminist criticism. Consequently, Millett has become the whipping girl for recent reexaminations of Lawrence's representations of sexuality and gender as well as for feminist criticism. What goes unnoticed in both cases, however, is the fact that Millett's account follows through on the critical terms of analysis set up by the critics from the Lady Chatterley trial itself. Lawrence critics have been so consumed with reclaiming Lawrence for the traditional canon that they have failed to pay attention to developments in the feminist canon. Millett's Sexual Politics may have helped spark the feminist move in the academy in the United States, but it is not a work that is part of the feminist canon today. As Carolyn Dever documents, Millett's text has been condemned by feminist critics for its extreme politics and its oversimplification of gender dynamics. Dever looks at what she terms the rise of "skeptical feminism" and how feminist ambivalence toward theory produces a paradox that Millett embodies: "Feminist theory is a form of authoritative discourse whose own authoritative implications must be undone as a function of its political critique" (3). For Dever, Millett creates a foundational feminist theory, but the very nature of feminism requires that theory must constantly be dismantled.
 What Millett did for Lawrence has now been done to Millett herself. She too has been censored for extremism, for her polemical tone, and for her simplified reading of gender (that excludes other identity categories). I wonder. Does this sound at all familiar? Many of the failings of Millett are often seen as the failings of Lawrence. It seems that the academy has a long history of turning its back on key figures in order to make allegorical examples. Without Lawrence, the literary critic may not have been validated. Without Millett, feminist politics as we know it may have been very different. Now, discussions of patriarchy are foundational to any women's studies course as well as basic literary studies classes. Generational conflict is necessary for any society, institution, or canon to grow, but I would advise us to know our history (as critics) a little better. One man is not responsible for misogyny just as one woman is not responsible for the downfall of feminism. By creating allegorical figures, we suggest that there is a correct value system (if not a moral system) in the academy. Through the polarizing representation of such literary or critical figures, we show that the academy is invested in censorship even if our own work as critics does not intend to do so.
 In looking over the course descriptions and syllabi at the University of Pennsylvania in the last year, Lawrence is absent from undergraduate and graduate courses. In the Columbia archive for the past three years, Lawrence only appears in one syllabus.
 "Odour of Chrysanthemums" as well as essays on the form of the novel appear in both the Longman and the Norton Anthologies. Both anthologies also include a varied selection of Lawrence's poetry. The Norton Anthology also includes the "Horse Dealer's Daughter," which does explore gendered relationships between men and women; however, Mabel is not presented as complex a figure as say Ursula in The Rainbow or Women in Love. In fact, Mabel would support some of the overly reductive arguments about representations of women in Lawrence.
 In the introduction to Reclaiming Lawrence and in the text itself, both Sandra Gilbert and Gary Adelman discuss the declining appearance of Lawrence in the teaching curriculum.
 Simon Wortham examines the submission process at PMLA that does not allow multiple submissions. In effect, the MLA participates in a form of censorship that is a "crucial factor in the production of social (and academic) discourse and knowledge" (Wortham 501, emphasis original).
 The transcript of the Lady Chatterley trial published by Penguin books details the testimony of a number of literary critics. See also Elisabeth Ladenson, Fiona Beckett, Damian Grant, and Sean Matthews.
 Notably, feminist critics like Elaine Showalter argue for an expansion of the canon in order to include female authored or themed texts that have otherwise been dismissed by literary scholarship.
 Valerie Lehr explores the importance of family in creating the nuclear family, Lisa Duggan explores the current cultural debate surrounding the move for gay marriage while considering the historical function of marriage, and David L. Eng argues for the "feeling of kinship" or kinship patterns based on choice rather than biological and legal factors. All three queer theorists see the institution of marriage as problematic due to its links to both state and church and its reinforcement of heteronormative/biological family structures. Similarly, Lee Edelman explores Western culture's investment in the child as part of "reproductive futurism." Ultimately, the rhetoric of the child reinforces a heteronormative idea of family and future. All of these theorists, like Lawrence, challenge the institution of marriage based on sexuality and desire.
 In Essentially Speaking, Diana Fuss argues that French feminists employed essentialism as a strategy to combat the patriarchal implications of public discourse.
 Jane Gallop details the institutionalization of the feminist canon while Sheila Jeffreys and Patricia Ticineto Clough detail the developments in the feminist canon related to Millett specifically.
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Erin K. Johns Speese recently completed her Ph.D. at West Virginia University. Her current project, entitled The Modernist Sublime: Parenthood and the Intersubjective Sublime Subject in Faulkner, Forster, Lawrence, and Woolf, explores how modern novelists reimagine the sublime experience between two Victorian parents as an intersubjective and empathetic experience. She has published essays on Mary Hays's The Victim of Prejudice, the television show Gilmore Girls, and the movie No Country for Old Men.