Most ACLU funding came from philanthropies, such as the Garland Fund. Free speech era In the 1920s, government censorship was commonplace. Magazines were routinely confiscated under the anti-obscenity Comstock laws; permits for labor rallies were often denied; and virtually all anti-war or anti-government literature was outlawed. Right-wing conservatives wielded vast amounts of power, and activists that promoted unionization, socialism, or government reform were often denounced as un-American or unpatriotic. In one typical instance in 1923, author Upton Sinclair was arrested for trying to read the First Amendment during an Industrial Workers of the World rally. ACLU leadership was divided on how to challenge civil rights violations. One faction, including Baldwin, Arthur Garfield Hays, and Norman Thomas, believed that direct, militant action was the best path. Hays was the first of many successful attorneys that relinquished their private practices to work for the ACLU. Another group, including Walter Nelles and Walter Pollak, felt that lawsuits taken to the Supreme Court were the best way to achieve change. During the 1920s, the ACLU's primary focus was on freedom of speech in general and speech within the labor movement particularly. Because most of the ACLU's efforts were associated with the labor movement, the ACLU itself came under heavy attack from conservative groups, such as the American Legion, the National Civic Federation, and Industrial Defense Association and the Allied Patriotic Societies. In addition to labor, the ACLU also led efforts in non-labor arenas, for example, promoting free speech in public schools. The ACLU was banned from speaking in New York public schools in 1921. The ACLU, working with the NAACP, also supported racial discrimination cases. The ACLU defended free speech regardless of espoused opinions. For example, the reactionary, anti-Catholic, anti-black Ku Klux Klan (KKK) was a frequent target of ACLU efforts, but the ACLU defended the KKK's right to hold meetings in 1923. There were some civil rights that the ACLU did not make an effort to defend in the 1920s, including censorship of the arts, government search and seizure issues, right to privacy, or wiretapping. Government officials routinely hounded the Communist Party USA, leading it to be the primary client of the ACLU. At the same time, the Communists were very aggressive in their tactics, often engaging in illegal conduct such as denying their party membership under oath. This led to frequent conflicts between the Communists and ACLU. Communist leaders sometimes attacked the