Holder v. Humanitarian Law Project, 561 U.S. 1 (2010), was a case decided in June 2010 by the Supreme Court of the United States regarding the Patriot Act's prohibition on providing material support to foreign terrorist organizations (18 U.S.C. § 2339B). The case, petitioned by United States Attorney General Eric Holder, represents one of only two times in First Amendment jurisprudence that a restriction on political speech has overcome strict scrutiny. The other is Williams-Yulee v. Florida Bar. The Supreme Court ruled against the Humanitarian Law Project, which sought to help the Kurdistan Workers' Party in Turkey and Sri Lanka's Liberation Tigers of Tamil Eelam learn how to resolve conflicts peacefully. It concluded that the US Congress had intended to prevent aid to such groups, even for the purpose of facilitating peace negotiations or United Nations processes because that assistance fit the law's definition of material aid as "training," "expert advice or assistance," "service," and "personnel." The finding was based on the principle that any assistance could help to "legitimate" the terrorist organization and free up its resources for terrorist activities. The court noted that the proposed actions of the Humanitarian Law Project were general and "entirely hypothetical" and implied that a post-enforcement challenge to the application of the "material support" provisions was not prevented. Reception Former President Jimmy Carter criticized the decision and argued: Élisabeth Decrey Warner, the president of the Swiss NGO Geneva Call, also expressed her disapproval by stating, "Civilians caught in the middle of conflicts and hoping for peace will suffer from this decision. How can you start peace talks or negotiations if you don't have the right to speak to both parties?" In January 2011, David D. Cole, a professor of law at Georgetown University Law Center, who argued the case for the Humanitarian Law Project, commented on developments since the decision. He noted that several prominent former officeholders, including Rudolph Giuliani and Tom Ridge, had spoken in support of the People's Mujahedin of Iran, an Iranian opposition group designated by the United States as a terrorist organization. He stated that he supported their right to speak but that even nonviolent advocacy, such as urging a designation as "terrorist" to be revoked, was illegal under the Supreme Court decision. He also pointed to exemptions granted under the rubric of "humanitarian aid" that turned out to include products like cigarettes and chewing gum. He stated, "Under