In July 1990, after National Endowment for the Arts chairman John Frohnmayer claimed that the NEA had never funded performance artist Annie Sprinkle, an ex-prostitute and self-proclaimed "postporn modernist," documents were found proving that a $60,000 grant had indeed funded Sprinkle's 12 performances at the Kitchen Theater in New York. In these performances, Sprinkle used dildos to simulate oral sodomy on stage and invited audience members to use a flashlight to peer up her vagina.

After rejecting Karen Finley for a grant the same month, the NEA gave grants to several theaters with the knowledge that she would perform there with NEA funds. Finley's performances feature her smearing her bare chest with chocolate syrup and alfalfa sprouts (representing sperm) to express "rage against sexual violence and women's objectification."

Tim Miller and Holly Hughes, two other performance artists, sued the NEA for denying them grants, claiming their First Amendment rights to free expression were violated. A solo performance by Hughes, "World Without End," included the artist's putting her hand up her vagina to show how her mother imparted the "secret meaning of life." The NEA gave Hughes a $15,500 playwriting fellowship to finish writing the very play that it refused her a grant to perform.

†