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Most historians consider the first American stag film to be A Free Ride, produced and released in 1915. The earliest known film to depict hardcore gay (and bisexual) sexual activity was the French film Le ménage moderne du Madame Butterfly, produced and released in 1920. The first known pornographic film appears to have been made in Europe in 1908. However, hardcore pornographic motion pictures ( stag films, as they were called prior to their legalization in 1970) were produced relatively early in the history of film. This is no longer the case in the United States, since such laws were ruled unconstitutional by the Supreme Court in 2003 in Lawrence v. In particular, gay material might constitute evidence of an illegal act under sodomy laws in many jurisdictions. During much of that time, any sexual depiction had to remain underground because of obscenity laws. Homoeroticism has been present in photography and film since their invention. Eakins himself appears in the water at bottom right – "in signature position, so to speak." According to Jonathan Weinberg, The Swimming Hole marked the beginning of homoerotic imagery in American art. The painting has been "widely cited as a prime example of homoeroticism in American art".
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