Obscenity prosecution for underground comix fell on the news vendor, not the artist.
Evidence
A strong draughtsman with a taste for heavy lines, expressionist angles, and outré mayhem, Spain was himself something of an outlaw, having, around the time of the Garbage Strike, precipitated EVO’s first bust. Published in the paper’s February 2 edition, the second panel of Spain’s Brink of Doom Comix had the anti-hero on his knees before a stoical female captive, exuberantly performing cunnilingus, the act emphasized with the words slurgh, shlosh, slurp! Someone complained and a Brooklyn news vendor was busted for selling obscene material. — J. Hoberman, Everything Is Now, 1254