Finnish Federation to its ranks, while the underground party withered and died, put to bed for good in 1923. Thereafter Ruthenberg was the sole Executive Secretary of the American Communist Party (still calling itself the Workers Party of America) — a position which he retained for the rest of his life, despite spending much of the 1920s as a leader of a minority faction within the party. The criminal anarchism convictions of Ruthenberg and Ferguson were ultimately overturned by the New York Supreme Court In July 1922, just in time for another round of prosecutions, this time related to ill-fate August 1922 Unity Convention of the CPA held at Bridgman, Michigan. 1922 Bridgman Convention and its aftermath A secret conclave had been arranged at the Wolfskeel Resort on the wooded shore of Lake Michigan to finally unite the CPA with a parallel organization maintained by its dissident Central Caucus faction. The site was regarded as relatively safe, having previously been used for a secret convention of the United Communist Party in the spring of 1920. This time, however, an informant of the US Department of Justice had managed to win election to the gathering as a delegate and the authorities had been notified. The forced merger did not, however, end the rivalries between the two groups. Ruthenberg and his supporter Jay Lovestone were at odds with a rival faction led by William Z. Foster, who had strong ties to organized labor and who wanted to direct the party's work toward organizing within the American-born working class, and James P. Cannon, who led the International Labor Defense organization. Ruthenberg ran unsuccessfully for a seat in the U.S. House of Representatives from Ohio's 20th congressional district (now abolished) as the candidate of the Workers Party of America, as the CPUSA's legal organization was then known, on his return to the United States. In 1925, Comintern representative Sergei Gusev ordered the majority Foster faction to surrender control to Ruthenberg's faction; Foster complied. The factional infighting within the CPUSA did not end, however; the communist leadership of the New York locals of the International Ladies' Garment Workers' Union lost the 1926 strike of cloakmakers in New York City in large part because of intra-party factional rivalries, as neither group wanted to take the responsibility for accepting a strike settlement that appeared insufficiently revolutionary . In 1926–27 his First Amendment case, Ruthenberg v. Michigan, was