This cover was controversial not because of who was on it—Sarah Kozer, the woman from forgettable reality show Joe Millionaire—but because of who wasn't. The cover of the June issue had customarily been the privilege of the Playmate of the Year, a tradition that seemed important to die-hard Playboy fans who see the Playmates as celebrities.
But to those unfamiliar with the Playboy universe, a Playmate, even the Playmate of the Year, is just a nude woman. The industry belief is that celebrities sell magazines—this applies to everyone, be it Vogue, GQ, or Cigar Aficionado—so 2003 PMOY Christina Santiago lost her cover shot to whats-her-name from Joe Millionaire.
Playboy devotees were outraged, and had another item to add to their ever growing list of grievances about what's wrong with Playboy today. Since 2003, a few PMOY's have made the cover, but it's no longer the automatic reward it had been. It's more likely a sign that the magazine failed to wrangle a decent celebrity that month.