In 1919 American Communist Party member Benjamin Gitlow was arrested for distributing a Left Wing Manifesto, a publication inspired by the Russian Revolution. He was charged with violating New York's Criminal Anarchy Law of 1902, which outlawed the advocacy of any doctrine advocating to the violent overthrow of government. Gitlow argued that the law violated his right to free speech but was still convicted. He appealed and five years later the Supreme Court upheld his sentence by a vote of 7-2. pThroughout the legal proceedings, much attention was devoted to the bad tendency doctrine--the idea that speakers and writers were responsible for the probable effects of their words--which the Supreme Court explicitly endorsed in its decision. According to Justice Edward T. Sanford, A state may punish utterances endangering the foundations of organized government and threatening its overthrow by unlawful means. pMore important was Justice Oliver Wendell Holmes' dissent, in which he argued that