1935 June 8

Young Nazi Guilty of Posting Inflammatory Sign; Hate Speech Controversy Ahead


Raymond Healey, 2 year-old member of the National Socialist Workers Party of America, was convicted on this day of posting an inflammatory pro-Nazi sign in the Yorkville neighborhood of New York City. He was convicted of disorderly conduct, even though posting the sign was his only act.

The pro-Nazi rally attracted a crowd of anti-Nazi protesters, and provoked a small riot. Julius Alexander was arrested for ripping down Healey’s sign, but the judge dismissed the charges.

The rise of domestic Nazi groups in the U.S. following Adolph Hitler’s coming to power in Germany in 1933 raised the issue of whether the First Amendment protected hate speech. After some debate, the ACLU on April 30, 1934 adopted a policy arguing that the First Amendment did protect freedom of speech and assembly no matter how offensive the speech or the beliefs of the group might be.

A major controversy erupted in the 1970s when on October 4, 1976 a small American Nazi group asked for a permit for a demonstration in Skokie, Illinois, a heavily Jewish community which included many Holocaust survivors. The controversy ended when the Seventh Circuit Court of Appeals upheld the First Amendment rights of the Nazi group on May 22, 1978.

Learn more: Samuel Walker, Hate Speech: The History of an American Controversy (1994)

Read: Philippa Strum, When the Nazis Came to Skokie: Freedom for the Speech We Hate (1999)

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