Used to convict anti-war speakers based not on advocacy/ opinion, but on effect of words:
- Frohwerk (HOLMES 1919) – Court upholds conviction for publishing and circulating twelve newspaper articles. Debs (HOLMES 1919) – leader and presidential candidate for socialist party. Court upheld conviction for inciting insubordination, disloyalty, mutiny, and refusal of duty in armed forces when delivering speech at state convention.
- Abrams (CLARKE 1919) - Russian immigrants wrote and distributed circulars advocating workers to stop producing weapons to be used against the Russian revolutionaries. HOLMES dissented based on intent and immediacy. No immediate danger caused by the “publishing of a silly leaflet by an unknown man.” & no specific intent. Ds intended to protect Russian revolutionaries, not to interfere w/ German war efforts.
Gitlow/Whitney 1925 - Clear and Present Danger 2.0
- red scare, laws banned certain classes of speech rather than looking at incitement to violence. Holmes dissented/concurred, arguing the CPD test requires immediate violence. Courts later followed Holmes/Brandeis reasoning.
- In contrast to Schenck/Debs, etc., in Gitlow/Witney, the forbidden act is the speech itself. Thus, the proximity inquiry of clear and present danger doesn’t work.
Gitlow (SANFORD 1925) –member of the socialist party, charged with criminal anarchy for publishing an article called Left Wing Manifesto. The Court upholds the statute saying that legislative determination that the speech was “so inimical to the general welfare and involve such danger of substantive evil” is entitled to judicial deference. HOLMES dissent argues that the legislature was not after speech, but the.