the conviction in 1940. But three years later, in West Virginia State Board of Education v. Barnette, the Supreme court reversed itself and wrote, "If there is any fixed star in our constitutional constellation, it is that no official, high or petty, can prescribe what shall be orthodox in politics, nationalism, religion, or other matters of opinion or force citizens to confess by word or act their faith therein." To underscore its decision, the Supreme Court announced it on Flag Day. Communism and totalitarianism The rise of totalitarian regimes in Germany, Russia, and other countries that rejected freedom of speech and association greatly impacted the civil liberties movement in the US; anti-Communist sentiment rose, and civil liberties were curtailed. The ACLU leadership was divided over whether or not to defend pro-Nazi speech in the United States; pro-labor elements within the ACLU were hostile towards Nazism and fascism and objected when the ACLU defended Nazis. Several states passed laws outlawing hate speech directed at ethnic groups. The first person arrested under New Jersey's 1935 hate speech law was a Jehovah's Witness who was charged with disseminating anti-Catholic literature. The ACLU defended the Jehovah's Witnesses, and the charges were dropped. The ACLU defended numerous pro-Nazi groups, defending their rights to free speech and free association. In the late 1930s, the ACLU allied itself with the Popular Front, a coalition of liberal organizations coordinated by the United States Communist Party. The ACLU benefited because affiliates from the Popular Front could often fight local civil rights battles much more effectively than the New York-based ACLU. The association with the Communist Party led to accusations that the ACLU was a "Communist front", particularly because Harry F. Ward was both chairman of the ACLU and chairman of the American League Against War and Fascism, a Communist organization. The House Un-American Activities Committee (HUAC) was created in 1938 to uncover sedition and treason within the United States. When witnesses testified at its hearings, the ACLU was mentioned several times, leading the HUAC to mention the ACLU prominently in its 1939 report. This damaged the ACLU's reputation severely, even though the report said that it could not "definitely state whether or not" the ACLU was a Communist organization. While the ACLU rushed to defend its image against allegations of being a Communist front, it also protected witnesses harassed by the HUAC. The ACLU was one of the few