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BEYOND SEX: EXPANDING USES OF NUDITY IN TWENTY-FIRST

CENTURY AMERICAN THEATRE

Marjorie Heins

Belin | « Revue française d’études américaines »

2022/2 N° 171 | pages 11 à 24


ISSN 0397-7870
ISBN 9782410025705
DOI 10.3917/rfea.171.0011
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Beyond Sex: Expanding Uses


of Nudity in Twenty-First Century
American Theatre
MARJORIE HEINS

Keywords Désormais, dans le théâtre américain, le recours à la


nudité va bien au-delà des stripteases aguicheurs du début
theatre; nudity; du XXe siècle. La nudité est devenue un moyen d’explora-
highbrow; lowbrow; tion de divers sujets comme la fragilité de l’amour, l’igno-
avant-garde; rance des professions médicales, l’esclavage, le racisme, les
Broadway; pandering; défis de l’intimité sexuelle. Au cours du temps, la distinc-
intimacy tion entre la culture érudite et la culture de masse est deve-
nue de plus en plus ténue. De plus, une nouvelle profession,
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celle d’intimacy director a émergé en réponse au mouve-
ment #MeToo afin de contrôler la façon dont la nudité
est exposée. Cet article poursuit la réflexion proposée dans
l’ouvrage Sex, Sin, and Blasphemy (1993) de la même
autrice.

In 1991, the Boise, Idaho Shakespeare Festival was preparing to present


Frank Wedekind’s Spring Awakening, a late nineteenth century drama
about adolescent sexuality and rebellion. Learning that the production
would include brief nudity, the festival board ordered the director to elim-
inate it. He resigned instead, and Spring Awakening was cancelled (Heins,
1993 107-08). It was a common enough scenario, an example of both the
continuing power of the naked body to stoke anxiety, and the ways in
which American theatre was changing.
This article begins with a discussion of how the uses of nudity 1
in live performance expanded in mid-to-late twentieth century America,
including, notably, its migration from avant-garde to mainstream enter-
tainment. There follows an examination of early twenty-first century pro-
ductions that radically enlarged the dramatic possibilities of nudity, to

1. I use the term “nudity” to encompass both total nakedness and near-naked-
ness—that is, the use of pasties, G-strings, or other minimal accessories.

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MARJORIE HEINS

explore, among other themes, the foibles of a male-dominated medical


profession and the explosive convergence of race and sex. Into this mix
came the new profession of “intimacy director,” to help navigate the poli-
tics of the #MeToo world. Section III goes on to examine the collapse
of distinctions between “highbrow” and “lowbrow” theatre, in contexts
ranging from downtown New York art venues to decisions of the U.S.
Supreme Court.
Today, theatre nudity has become almost routine in the United
States. In the process, its uses have greatly expanded—to address issues
of racism, sexism, vulnerability, and desperation, in addition to its age-
old themes of openness, pleasure, and sex.

Stirrings of Change
In the latter decades of the twentieth century, American theatre
began to use nudity for purposes well beyond the titillating and often
elaborately produced striptease acts of the 1920s-1940s. 2 Prominent
among the early game-changers were Julian Beck and Judith Malina’s
off-off Broadway Living Theatre and the solo performance pioneer Car-
olee Schneemann. In 1968, the Living Theatre toured Paradise Now, a
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semi-improvisational piece that was much influenced by Antonin
Artaud’s theory of a Theatre of Cruelty, with its emphasis on collapsing
the fourth wall—the barrier between actors and audience. The play
included a “Rite of Universal Intercourse” in which actors disrobed while
inviting the audience to join them. They wore G-strings to avoid arrests
for indecent exposure (Penner 83).
Carolee Schneemann’s performances were more intentionally femi-
nist. In her 1975 Interior Scroll, she stood nude on a table, enumerating
the misogynistic attacks that a woman artist could expect, then pulling a
scroll from her vagina and reading a rebuttal to a critic who had derided
her work (Cotter; Solly). Schneemann’s earlier (1964) Meat Joy was “an
hour-long, bacchanalian celebration of the flesh, [with] … men and
women cavorting around in various stages of undress while slathering
each other in paint and exchanging slimy handfuls of raw fish, chicken
and sausage” (Solly). She explained Meat Joy as “an erotic ritual for my
starved culture … worship of nature, worship of the body, a pleasure in
sensuousness.” (Solly) One scholar describes Schneemann and the Living

2. The extravagantly produced Ziegfeld Follies arrayed its performers as precision danc-
ers, scantily clad but not fully nude. In the more blatantly risqué art form of striptease, the
headliners revealed just about everything, and often created comic song-and-dance routines
to accompany their disrobing (Shteir).

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EXPANDING USES OF NUDITY IN TWENTY-FIRST CENTURY AMERICAN THEATRE

Theatre as examples of “mythic nudity,” in which the body signifies “pri-


mordial human innocence” (Toepfer 78).
Director Peter Brook was equally a pioneer with his 1966 Broadway
production of Peter Weiss’s The Persecution and Assassination of Jean-
Paul Marat as Performed by the Inmates of the Asylum of Charenton under
the Direction of the Marquis de Sade (Marat-Sade, for short), a British
import whose brief nudity had little to do with primordial human inno-
cence. The Brecht-influenced play within a play culminates in the 1793
assassination of Jacobin revolutionary Jean-Paul Marat in his bathtub by
the Girondist Charlotte Corday. In a dream sequence, Marat floats in a
steamy tank, then emerges nude before returning to his tub. He is
“‘stripped of his sanity and his philosophy and stands there completely
naked’” 3 (Outwater). Marat.Sade won four Tony awards, including Best
Play and Best Director.
Marat.Sade, Paradise Now, and Schneemann’s solo shows were all
avant-garde offerings, but in 1967 theatrical nudity hit the mainstream
with the “American Tribal Love Rock Musical” Hair. Its quintessentially
1960s portrayal of peace, love, and hippiedom seems almost quaint today,
but at the time, its celebration of drug use and its irreverence for
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the American flag at a moment of intense antagonisms over the Vietnam
War caused as much controversy as its brief nude scene. Hair opened at
Joseph Papp’s off-Broadway Public Theatre, moved to Broadway in April
1968, and ran for 1,750 performances, followed by many regional produc-
tions (Playbill; Horn 110-25). Hair was the first Broadway show with full
frontal nudity, male and female (Horn 59).
Hair’s successor, the artistically disastrous Oh! Calcutta! (a play on
the French “oh, quel cul t’as!”) boasted significantly more nudity but its
series of lame skits about the cultural curiosities of modern sexual behav-
ior were amateurish and sophomoric. Oh! Calcutta! did have one entranc-
ing nude pas de deux, and regardless of its overall silliness, it became
Broadway’s longest-running show up to that time (7,275 performances,
counting the initial 1969-72 run and a 1976 revival (Playbill)).
After Hair and Oh! Calcutta! the barriers were down. Peter Shaffer’s
Equus opened on Broadway in 1974; its over-the-top psychological drama
concerned a teenage boy obsessed with horses who blinds a stable full of
them after he’s unable to manage sex with a girl; the boy is nude after
the aborted sex scene (Shaffer 105). Terrence McNally’s Frankie and
Johnny in the Clair de Lune debuted on Broadway in 1987 and has had
many revivals in recent decades; it begins with two lovers loudly enjoying

3. Quoting George Miller, director of a 1995 regional production.

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simultaneous orgasms; then they emerge nude from bed, but the play is
less about sex than about an insistent man who pushes his lover to shed
her defenses and really “connect” (McNally). Tony Kushner’s epic Angels
in America opened on Broadway in 1993 after productions in San Fran-
cisco, Los Angeles, and London; it interweaves stories of gay lovers, one
suffering from AIDS, with themes of the cultural divide between middle
America and bohemian New York, and of the anti-communist purges of
the 1950s and their continuing shadow over American politics. Angels has
two nude scenes: in one, the AIDS-stricken character is in his doctor’s
office; the nudity graphically conveys his desperate situation. In the other,
a previously closeted man strips before his lover on a freezing beach—not
a hospitable place for seduction. The point is that he’s symbolically shed-
ding his fundamentalist Mormon past (Kushner 101, 206). Brilliantly
conceived and ambitious in scope, Angels also continues to be performed
in the twenty-first century.

The New Millennium


Barely had the 2000s begun than Mary Zimmerman’s Metamorpho-
ses came to off Broadway in 2001, then to Broadway the next year. Based
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on nine stories from Ovid’s Metamorphoses, Zimmerman’s play mixes
ancient myths with modern routines such as a psychotherapist analyzing
the teenage rebellion issues of the sun god Apollo’s son Phaeton. It makes
for a lot of humor if done well; both humans and gods appear in scanty
outfits that conjure up the ancient Greek and Roman idealization of the
well-proportioned human form. Only Eros appears fully nude (although
with strap-on wings). In a Q and A dialogue during the episode of Eros
and Psyche, Zimmerman explains the reason for the god’s nudity. The
questioner asks: “Why is he naked?” The reply: “To make us transparent.
… Transparent in our love. Foolish to others. Exposed” (Zimmerman
68).
Eros’s nudity wasn’t a problem on the New York stage but, like
many shows before and since, there were jitters—and loincloths—when it
went on the road to other American cities. A frequent concern was that
organizers of school groups would not buy tickets. Zimmerman
responded that parents and teachers should probably be more concerned
about the episode of Myrrha, who has sex with her father. As Zimmer-
man said, it’s “far more risqué because it is erotic and deals with incest.”
Eros’ nudity, by contrast, is “‘easeful and decidedly not erotic: ‘it feels
like a sacred scene’” (Kaissar).
Another popular play with a naked male posed considerably more
fraught questions of history and politics. Sarah Ruhl’s In the Next Room,

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or the vibrator play debuted in Berkeley, California in 2009 and came to


Broadway later that year. The play addresses the history of the vibrator,
described in the nineteenth century as “therapeutic electrical massage”
and used by male physicians to give orgasms to neurotic women. But they
were called “paroxysms,” and almost nobody at the time saw them as
sexual (Hurwitt). The character of Dr. Givings, sure of himself and his
scientific expertise throughout the play, turns out to have been clueless
all along about those paroxysms, and about what many women were miss-
ing in bed. It is the women characters who not only achieve self-knowl-
edge but learn some exciting facts about their bodies.
The show ends with Mrs. Givings taking charge, undressing her hus-
band, and making love to him. The stage directions advise that “we don’t
need to see all of his body” (Ruhl 143); the important point is that he is
naked, for the first time in her presence—“naked in a liberating moment
of intimacy” with his wife (Kaissar). Despite its touchy subject, In the
Next Room was one of the most frequently produced works at profes-
sional theatres across the United-States in the 2010-11 and 2011-12 sea-
sons (Hurwitt).
The perennially popular Frankie and Johnny in the Claire de Lune
had Broadway revivals in 2002 and again in 2019. By the time of the
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second revival, a new business had emerged on the theatrical scene: the
“intimacy director.” In response to the #MeToo movement, theatre activ-
ists had created an organization called Intimacy Directors International,
and in 2019, it recommended one of its founders, the British actress and
stage fight director Claire Warden, to help out with Frankie and Johnny
(Intimacy Directors). The female lead, Audra McDonald, was nervous
about performing nude for the first time in her Tony Award-studded
career (Collins-Hughes).
One of the many articles detailing preparations for the Frankie and
Johnny nude scene noted that the lighting designer was also enlisted to
help McDonald feel comfortable: she “bath[ed] the set in moody light
that [gave] the actors someplace to hide” (Collins-Hughes). Did this light-
ing choice obscure the playwright’s intention? One critic thought so. “It’s
such a slick piece,” he said of the play in a conversation published on his
website; “I’m not sure any production could really salvage it, but certainly
not this one, which gives away the basic problem almost immediately: in
the coy way the nudity is handled, full of flattering shadows and angles”
(Fox).
Claire Warden worked on another, more confrontational production
off Broadway in 2018: Slave Play, by the young Black playwright Jeremy
O. Harris. It is set on a slave plantation, or at least initially seems to be,
where three interracial couples enact scenarios of sexual dominance and

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submission, complete with “the whip, the dildo, the nudity, the boots, the
bondage, the orgasms both achieved and aborted” (Green). It turns out
that they’re contemporary couples participating in “Antebellum Sexual
Performance Therapy.” The purpose of the therapy is to cure the Black
partners’ “anhedonia,” which the therapists attribute to “Racialized
Inhibiting Disorder” (Harris 104-05). The play’s title refers to sexual slav-
ery role-playing, and despite the satiric edge in Harris’s use of psychother-
apeutic and race theory jargon, the way that white privilege infects
interracial relationships comes through as deadly serious.
Slave Play was a succès de scandale off Broadway and moved to
Broadway in 2019. It certainly had its critics, including Black women who
objected to the perceived lighthearted depiction of slavery or the notion
that sexual problems could be resolved through master-and-slave role play
(Jones; Almonord). But the power of Harris’s theme was undeniable. The
New York Times raved that the third act was “a brilliant little play in
itself … as wrenching a portrait of moral gridlock as anything in Arthur
Miller, as weirdly lyrical as Tennessee Williams and as potently height-
ened as Suzan-Lori Parks” (Green). The cast members expressed grati-
tude for Intimacy Director Warden’s help in staging the sex scenes.
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Tracy Letts’s 2019 Linda Vista, in which nudity abounds, also had
an intimacy director: a dance therapist who had worked on six other
plays in the preceding year. She gave the actors “mental health tips and
tricks, including meditations, in case they find themselves feeling less than
OK.” And she was “a stickler for anatomically correct language,” forbid-
ding slang to refer to any body part (Gelt). The director of this purported
comedy about a foul-mouthed middle-aged misogynist, who manages to
get four different women into bed in the course of the play, thought the
nudity “especially effective in the context of a story about profound
human frailty” 4 (Gelt).

Highbrow, Low, and In Between


Despite the new-found sensitivity to the issue of sexual boundaries,
there was still plenty of pandering in American live performance. The
website of Nearly Naked Theater of Phoenix, Arizona, for example, had
a provocative, campy style that highlighted well-toned bodies and shouted
in upper case letters: “STRIPPED OF CONFORMITY, BARE AND
EXPOSED, PROVOCATIVE …”; yet it turned out that the name of
this nonprofit troupe was mostly a come-on, referring not to the actors’

4. Paraphrasing director Dexter Bullard.

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wardrobes or lack thereof but to the absence of lavish sets or other accou-
trements. At least some of its productions were major plays (Equus, for
example, or Christopher Marlowe’s Edward II). The company survived
for seventeen seasons, the last in 2017 (Nearly Naked).
Was Nearly Naked highbrow or lowbrow entertainment? The ques-
tion is beside the point. By combining serious theatre with promotion
that verged on soft-core pornography, Nearly Naked collapsed distinc-
tions between high and low.
A more clearly highbrow theatre company also was not above pan-
dering. When Chicago’s Writers Theatre staged one of America’s classics,
A Streetcar Named Desire, in 2010, the company designated its front row
“The Desire Seats” because they “offered unfettered sightlines to a nude
scene between Stanley and Stella. ‘We threatened to charge more,’” joked
the associate artistic director. They didn’t, but the production sold out,
and “the Desire Seats were always filled” (Kaissar).
In another manifestation of the power of eroticism to trump more
subtle dramatic concerns, theatre websites with comments about actors’
physical attributes have proliferated. During Angels in America’s many
revivals, fans compared nudity and body parts in American and British
productions and noted where to find the best seats for optimum viewing.
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One message board contributor, speaking of the London National Thea-
tre production, asked whether he might request a refund if he thought he
would get to see actor Andrew Garfield’s “man things,” but was disap-
pointed. (Broadway World) Of a 2012 Philadelphia production, a contrib-
utor to the Male Nudity in New York Stage website advised that “the best
view is on the audience left. The audience right will only get a view of
[one character’s] butt, which is still pretty amazing” (Reader’s Report).
All this erotic chatter might well be considered lowbrow, but it doesn’t
detract from the brilliance of Tony Kushner’s play. 5
A discussion of theatrical pandering in twenty-first century United-
States would not be complete without a mention of the notorious “war-
drobe malfunction” at the 2004 Super Bowl football half time show, when
pop singer Justin Timberlake not-so-accidentally ripped off part of Janet
Jackson’s bustier to momentarily reveal her right breast. Super Bowl half
time performances are traditionally raunchy, but it was the briefly bared
nipple that caused a public ruckus (Heins 2004). More than 71,000 people
attended this live sports event (Super Bowl) and 144 million others viewed

5. This form of fan appreciation was hardly new with Angels, nor was it exclusively
gay. In 1999, there was much excitement on the New York theatre scene about a brief
glimpse of Nicole Kidman’s bare bottom in David Hare’s The Blue Room, even though
Kidman “was bared for less time than it takes to change a light bulb” (Hirsch).

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it on TV (“2004”), including millions of children and teenagers. The half


time show has no pretensions to high art but it has serious value as
entertainment for millions of fans, and momentary nudity is the least of
its sins, yet that was the focus of partisan anger in 2004—a reflection of
the peculiarly American obsession with naked bodies, especially if chil-
dren or adolescents might see them.
Super Bowl antics notwithstanding, the distinction between high
and low art, erudition and pop culture, is a relatively recent historical
phenomenon. Until the twentieth century in the United States, Shake-
speare was popular entertainment (Levine). It was in the 1920s and ’30s
that the distinction developed, when an American social and intellectual
elite promoted the idea that serious homegrown drama could rival the
high culture of Europe and should not be confused with less elevated
cultural distractions (Savran 3). The highbrow/lowbrow distinction found
its way into the law in 1942 when the U.S. Supreme Court announced
that speech which is “no essential part of any exposition of ideas” does
not merit First Amendment protection 6 (Chaplinsky 572).
The distinction proved useful when the Supreme Court tackled the
tricky subject of obscenity law. How to reconcile the First Amendment
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with the apparent social imperative to control sexually explicit expres-
sion? And if “obscenity” is to be outside the protection of the First
Amendment, how to define it? The current definition, as proclaimed by
the Supreme Court in 1973, states in part that the First Amendment
protects sexually explicit material only if it has “serious political, artistic,
political, or scientific value.” Material without such “serious
value”—whether literary, visual, or theatrical—can be banned or pun-
ished as obscene. (Miller 23-26) But who is to decide this question of
“serious value”? Prosecutors, judges, and juries, with a last-resort arbitra-
tion of such aesthetic distinctions by the Supreme Court justices them-
selves. 7

6. Chaplinsky involved a criminal conviction for calling a policeman “a goddam fas-


cist” and “racketeer”; the Court said such “fighting words” lack First Amendment protec-
tion because they are “of such slight social value as a step to truth that any benefit that
may be derived from them is clearly outweighed by the social interest in order and moral-
ity” (Chaplinsky 572).
7. The 1973 Miller decision loosened what had been a tighter test for obscenity: in
1957, a more liberal Supreme Court had ruled that ideas “having even the slightest redeem-
ing social importance” are constitutionally protected (Roth 484). This principle that
obscenity prosecutions must be limited to material that is “utterly without redeeming social
importance” opened the door to much art and literature that had been suppressed, includ-
ing the unexpurgated Lady Chatterley’s Lover (Rembar).

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With specific respect to theatre, the Supreme Court applied its dis-
tinction between highbrow (or at least middlebrow) productions and pre-
sumably less worthy ones in two cases. The first, in 1975, involved Hair,
which had been touring smaller cities for a number of years when it came
to Chattanooga, Tennessee. City officials, deeming the show obscene,
denied its producers use of the municipal theatre. The producers chal-
lenged the refusal, and when the case got to the Supreme Court, the
justices ruled that Chattanooga had failed to follow procedures that the
First Amendment requires before imposing a “prior restraint”—that is,
essentially banning the production. Underlying the decision was a pre-
sumption that this piece of controversial but mainstream American thea-
tre had full First Amendment protection; as the justices said: “Only if we
were to conclude that live drama is unprotected by the First Amend-
ment—or subject to a totally different standard from that applied to
other forms of expression—could we possibly find no prior restraint here”
(Southeastern Promotions 557).
The Court took a drastically different approach in 1991 when erotic
dancers at South Bend, Indiana’s Kitty Kat Lounge challenged a law
requiring them to wear pasties and G-strings. Chief Justice William Rehn-
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quist’s opinion reluctantly acknowledged the sexual message of nude
dancing but called it “expressive conduct within the outer perimeters of
the First Amendment.” This notion of an “outer perimeter” of constitu-
tional protection enabled him and two of his fellow justices to opine
that the pasties and G-string requirement “does not deprive the dance of
whatever erotic message it conveys; it simply makes the message slightly
less graphic” 8 (Barnes 571). For judges to decide how best to convey an
artistic message is a dubious prospect indeed, and Rehnquist could not
have done it if he had not already, in a moment of highbrow snobbery,
relegated nude dancing to “the outer perimeters of the First
Amendment.”
Solo performance has provided one of the most dramatic illustra-
tions of the difficulty of maintaining a highbrow/lowbrow distinction. By
the end of the twentieth century, sex-positive artists in the tradition of
Carolee Schneemann were using nudity to protest such evils as homopho-
bia, violence against women, and the scourge of AIDS. Karen Finley,
whose piece We Keep Our Victims Ready led to her being labeled by the

8. Two other justices concurred in the result without agreeing with Rehnquist’s reason-
ing. Antonin Scalia thought that moral opposition to nudity was sufficient to uphold the
law. David Souter thought the law could be justified because nude dancing venues are
associated with seedy neighborhoods

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mass media as “the nude, chocolate-smeared woman,” 9 gained fame


beyond the downtown New York world of performance art when she and
three other performers were denied grants that had been recommended
by a National Endowment for the Arts (NEA) peer panel amid a blizzard
of sensationalist publicity (Dubin 145-58; Heins 1993, 117-36). Tim
Miller, another of the “NEA Four,” 10 was equally provocative: “getting
buck naked in almost every show and sitting in laps or coaxing an erec-
tion.” In one piece, “Miller argues with his ‘forlorn’ penis: ‘Are you trying
to make me look bad?’ he asks. ‘Get hard!’” Nudity was “one his ‘many
little activisms,’” Miller told a reporter. “‘There is almost no public space
in our country where people can be naked—nude beaches and the theater,
and that’s it. Whenever we’re more fucked up than England, it’s always
a cause for concern’” (Bunn). Both Miller and Finley, as well as Schnee-
mann herself, continued to perform well into the twenty-first century
(Gambone; Elder; Pfahler; Liebert). 11
Solo theatre performance was not only sexually explicit: among its
practitioners were some genuine porn stars. The most prominent was
Annie Sprinkle, whose show Post Porn Modernist, which toured from
1989 to 2004, celebrated the female orgasm (she sometimes demonstrated
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by masturbating) and invited audience members to inspect her cervix.
Sprinkle, like Finley, performed at the downtown art space Franklin Fur-
nace, which became the target of journalistic attacks in 1990 for its per-
formers’ merging of pornographic tropes with sex positive feminist
messages (Dubin 148). Sprinkle was still at work in 2019, featuring some
of her theatrical props in an art exhibition; recounting her career, she told
an interviewer: “I’d like to think I brought the lowbrow into the high-
brow.” (Sayej) Certainly, like Finley and others on the solo performance
scene, she blurred the boundaries.

Although nudity in theatre has helped collapse distinctions between


high art and low, it continues to be jolting, as it should be. Whether at
Equus or Angels in America or a performance by Annie Sprinkle, we’re
not looking at photoshopped or airbrushed images on a screen; instead,

9. The chocolate was meant “as a symbol of women being treated like dirt” (Finley).
10. The other two of the NEA Four were gay artists Holly Hughes and John Fleck.
11. Carolee Schneemann’s influence has been huge. She was “at the forefront of move-
ments that only later came to be known as body art, performance art and feminist art,
paving the way for the likes of Marina Abramović, Cindy Sherman, Tracey Emin—and
even Lady Gaga” (Rose).

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EXPANDING USES OF NUDITY IN TWENTY-FIRST CENTURY AMERICAN THEATRE

we’re in the presence of human flesh, with all of its power to evoke feel-
ings of shock, intimacy, vulnerability, desperation, openness, and pleas-
ure. Theatre is “an open and total confrontation; that is its distinguishing
mark and chief glory.” (Kerr) And nudity, as one director puts it, is
“‘brutal in its honesty. … If it’s not used gratuitously, nudity has the
potential of elevating humanity’” (Kaissar). 12
From the mid-twentieth century to the present day, playwrights and
directors have enlarged the theatrical field on which nudity plays. Once
simply a sexual come-on in “lowbrow” American entertainment, today
both the symbolism and the emotive power of the nude human body are
used to make audiences think about a myriad of political and cultural
issues. If an element of sexual arousal—and, admittedly, of pander-
ing—sometimes accompanies this blurring of traditional boundaries
between high and low art, that may simply reflect the wisdom of the old
adage of the women’s liberation movement: the personal is political.

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12. Quoting Kim Weild, director of a 1997 Los Angeles production of Aeschylus’ The
Bacchae with—appropriately, given the subject matter—20 naked women.

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Court cases
Barnes v. Glen Theatre, 501 U.S. 560 (1991)
Chaplinsky v. New Hampshire, 315 U.S. 568 (1942)
Miller v. California, 413 U.S. 15 (1973)
Roth v. United States, 354 U.S. 476 (1957)
© Belin | Téléchargé le 29/06/2022 sur www.cairn.info par via Université de Tours (IP: 94.66.80.14)

© Belin | Téléchargé le 29/06/2022 sur www.cairn.info par via Université de Tours (IP: 94.66.80.14)
Southeastern Promotions, Ltd. V. Conrad, 420 U.S. 546 (1975)

24 No 171

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