Tropic of Cancer was published by Jack Kahane in 1934, and the book was summarily banned in Great Britain and the United States. This infamous ban was not lifted until the culmination of a protracted legal battle initiated by Barney Rossett and his Grove Press to publish the book in 1962. Miller left New York in the twenties to become a writer in Paris, and Tropic of Cancer is the account of his life as a struggling artist. The novel's graphic depiction of sex and its use of crude language was too much for the censors, but Tropic of Cancer was smuggled into the United States where it gained great notoriety. In a 1962 ruling that initiated changes in the laws of literary and artistic censorship, Judge Samuel B. Epstein found that Tropic of Cancer was not obscene. The legal battle for William Burroughs' Naked Lunch was soon to follow.