opposed by the fledgling American Civil Liberties Union and other libertarians of the time. Having read Chafee's article, Holmes decided to retroactively reinterpret what he had meant by "clear and present danger" and accepted Chafee's characterization of the new test in his dissent in Abrams v. United States just six months after Schenck. Schenck, Frohwerk, and Debs all resulted in unanimous decisions, while Abrams did not. Brandenburg For two decades after the Dennis decision, free speech issues related to advocacy of violence were decided using balancing tests such as the one initially articulated in Dennis. In 1969, the court established stronger protections for speech in the landmark case Brandenburg v. Ohio, which held that "the constitutional guarantees of free speech and free press do not permit a State to forbid or proscribe advocacy of the use of force or of law violation except where such advocacy is directed to inciting or producing imminent lawless action". Brandenburg is now the standard applied by the Court to free speech issues related to advocacy of violence. See also Imminent lawless action List of United States Supreme Court cases, volume 395 Shouting fire in a crowded theater Threatening the president of the United States Abrams v. United States, Brandenburg v. Ohio, Chaplinsky v. New Hampshire, Dennis v. United States, Feiner v. New York, Hess v. Indiana, Korematsu v. United States, Masses Publishing Co. v. Patten, (1917) Sacher v. United States, Schenck v. United States, Terminiello v. Chicago, Whitney v. California, Notes References Eastland, Terry, Freedom of Expression in the Supreme Court: The Defining Cases, Rowman & Littlefield Publishers, 16. August 2000, Finkelman, Paul (Editor), Encyclopedia of American Civil Liberties (two volumes), CRC Press, 2006, Kemper, Mark, "Freedom of Speech", in Finkelman, Vol 1, p 653–655. Killian, Johnny H.; Costello, George; Thomas, Kenneth R., The Constitution of the United States of America: Analysis and Interpretation, Library of Congress, Government Printing Office, 2005, Rabban, David, Free Speech in Its Forgotten Years, Cambridge University Press, 1999, Redish, Martin H., The Logic of Persecution: Free Expression and the McCarthy Era, Stanford University Press, 2005, Further reading Chester James Antieau, "The Rule of Clear and Present Danger: Scope of Its Applicability," Michigan Law Review, vol. 48, no. 6 (April 1950), pp. 811–840. In JSTOR Louis B. Boudin, "'Seditious Doctrines' and the 'Clear and Present Danger' Rule: Part I," Virginia Law Review, vol. 38, no. 2 (Feb. 1952), pp. 143–186.