without a judicial trial, and may be inflicted against an individual or a class (contrary to the majority's conclusion that it applies only to an individual). That Garland and Cummings involved professionals rather than laborers and that Garland and Cummings involved vague accusations of misconduct rather than the single specific accusation in Garner was irrelevant, Douglas said. Since the Los Angeles ordinance permitted no hearing, it was a bill of attainder and not constitutionally valid. Douglas did not reach the issue of whether the ordinance was an ex post facto law. Black's dissent Justice Black further dissented from the majority by making two additional points. First, he argued that the majority mischaracterized the decision in Gerende v. Board of Supervisors. The Maryland law in Gerende was limited to actual acts of violence or overthrow, while the Los Angeles ordinance was not. Second, Black believed that the majority's decision in Garner significantly weakened the Court's holdings in Ex parte Garland, Cummings v. Missouri, and United States v. Lovett. See also List of United States Supreme Court cases involving the First Amendment List of United States Supreme Court cases, volume 341 Footnotes Bibliography Rosenbloom, David and O'Leary, Rosemary. Public Administration and Law. 2d ed. Washington, D.C.: CRC Press, 1996. External links 1951 in United States case law United States Constitution Article One case law United States Supreme Court cases United States Supreme Court cases of the Vinson Court United States Free Speech Clause case law United States elections case law History of Los Angeles United States ex post facto case law Oaths of allegiance