On your first comment, yeah, I looked through the court's opinion and couldn't find that term anywhere. But the term "community standard" is included, and intended to mean a national, collective standard. But who is to judge that?
Moreover, just after your quoted bit is this.
"Sex and nudity may not be exploited without limit by films or pictures exhibited or sold in places of public accommodation any more than live sex and nudity can [413 U.S. 15, 26] be exhibited or sold without limit in such public places. 8 At a minimum, prurient, patently offensive depiction or description of sexual conduct must have serious literary, artistic, political, or scientific value to merit First Amendment protection."
The overall theme here, and as agreed in every write-up I've seen, is that to fall under the Miller Test, obscene material must travel through a public medium (could be postal service, potentially internet as well). So, in other words, if I were to draw some cp right now, drive it to you, and hand it to you in person, I would not be breaking the law (nor would you for possessing it). The question is, does an internet website count as a public medium? Peer-to-peer file sharing?
There are so many different ways to rip apart the Miller Test in this case that if any case actually went to court, it would be struck down.