v. New York (1925), the Court upheld the conviction, but a majority also found that the First Amendment applied to state laws as well as federal laws, via the Due Process Clause of the Fourteenth Amendment. Holmes and Brandeis dissented in several more cases in this decade, however, advancing the argument that the Free Speech Clause protected a far greater range of political speech than the Court had previously acknowledged. In Whitney v. California (1927), in which Communist Party USA organizer Charlotte Anita Whitney had been arrested for "criminal syndicalism", Brandeis wrote a dissent in which he argued for broader protections for political speech: Those who won our independence... believed that freedom to think as you will and to speak as you think are means indispensable to the discovery and spread of political truth; that without free speech and assembly discussion would be futile; that with them, discussion affords ordinarily adequate protection against the dissemination of noxious doctrine; that the greatest menace to freedom is an inert people; that public discussion is a political duty; and that this should be a fundamental principle of the American government. In Herndon v. Lowry (1937), the Court heard the case of African American Communist Party organizer Angelo Herndon, who had been convicted under the Slave Insurrection Statute for advocating black rule in the southern United States. The Court reversed Herndon's conviction, holding that Georgia had failed to demonstrate any "clear and present danger" in Herndon's political advocacy. The clear and present danger test was again invoked by the majority in the 1940 Thornhill v. Alabama decision in which a state antipicketing law was invalidated.The Court adopted the imminent lawless action test in 1969's Brandenburg v. Ohio, 395 U.S. 444 (1969), which some commentators view as a modified version of the clear and present danger test. The importance of freedom of speech in the context of "clear and present danger" was emphasized in Terminiello v. City of Chicago (1949) where the Supreme Court noted that the vitality of civil and political institutions in society depends on free discussion. Democracy requires free speech because it is only through free debate and free exchange of ideas that government remains responsive to the will of the people and peaceful change is effected. Restrictions on free speech are only permissible when the speech at issue is likely to produce a clear and present danger of a serious substantive