In 1920, a New York attorney whose daughter had received an unsolicited copy of The Little Review issue brought it to the attention of John S. Sumner, secretary of the New York Society for the Suppression of Vice.Marek 87Ellman (1982), pp. 502–04 Sumner lodged a complaint that September, and on October 4 Anderson and Heap were arrested and charged with obscenity for publishing "Nausicaa" in the April 1920 issue of The Little Review."Ulysses, Episode XIII", The Little Review Vol. VI, No. 11, p. 42. April 1920. This episode was an account of protagonist Leopold Bloom fantasizing about a young girl named Gerty MacDowell who leans back to expose herself to Bloom. The scene culminates in Bloom's orgasm, which legal historian Edward de Grazia, in Girls Lean Back Everywhere, argues would have likely escaped the average reader's notice due to Joyce's metaphorical language.de Grazia 9-10
