Anti-Defamation League Plains States Regional Director Corrects Statement on Free Speech:

The following was, I'm told by ADL headquarters, sent today to the Omaha World-Herald by Alan Potash, Director of the Plains States Regional Office of the Anti-Defamation League:

When I wrote to the Omaha World-Herald and said that “free speech does not extend to racist groups,” I misspoke. Free speech can and should extend to such groups. However, extremist or racist speech is not and should not be protected where it incites imminent lawless action that is likely to occur. ADL has a long history of defending free speech and we stand by our deep commitment to this fundamental principle of democracy. See e.g., Responding to Extremist Speech.

I'm pleased to hear it, and I agree that speech -- whether extremist or racist or not -- that "incites imminent lawless action that is likely to occur" is unprotected under Brandenburg v. Ohio (1969). I'm pretty sure that very little of the speech discussed in the Omaha World-Herald editorial to which Mr. Potash's initial statement referred would qualify under this narrow Brandenburg exception. But if indeed the exception is read as narrowly as the Court has read it (see, for instance, Hess v. Indiana (1973)), then I have no disagreement with Mr. Potash's corrected position.

Related Posts (on one page):

  1. Anti-Defamation League Plains States Regional Director Corrects Statement on Free Speech:
  2. Anti-Defamation League Regional Director Asserts That "Freedom of Speech Does Not Extend to Racist Groups":
James Eaves-Johnson (mail) (www):
Alan Potash has done a lot of good work in the area where I live (in Eastern Iowa) and this correction is a welcome response. The Great Plains region is a large area and in many areas there is weak community support for Jews who face antisemitism. Alan is an important part of how we fill that gap. It is good to see that he protects his credibility when it is called into question.
7.1.2009 4:05pm
SuperSkeptic (mail):
Overrule Chaplinsky. Resurrect J. Black. Allow people to freely enter the "marketplace of ideas" at their own risk. Okay, go ahead and yell "fire" at a movie theater, but be prepared to pay the consequences, in liability for injuries or otherwise that result. "Congress shall make no law..."
7.1.2009 4:10pm
Ex-Fed (mail) (www):
Allow people to freely enter the "marketplace of ideas" at their own risk. Okay, go ahead and yell "fire" at a movie theater, but be prepared to pay the consequences, in liability for injuries or otherwise that result. "Congress shall make no law..."



Of course, the process for assigning and adjudicating "liability for injuries" operates by force of law, making that distinction elusive at best.
7.1.2009 4:13pm
SuperSkeptic (mail):
Of course, the process for assigning and adjudicating "liability for injuries" operates by force of law, making that distinction elusive at best.

Is that not what "proximate cause" is all about?
7.1.2009 4:19pm
Kazinski:
I think I would favor a more common sense rule that is very close to what Alan Potash's original statement meant. Which is basically:

Speech I find objectional with should be permitted; Speech I don't find objectional with should be banned.



There. That's clear isn't it? That would solve that T-shirt problem from yesterday too.
7.1.2009 4:23pm
Ex-Fed (mail) (www):
Is that not what "proximate cause" is all about?



"Proximate cause" is but one necessary concept. If you reveal to the world that I am a liar and an idiot, I may proximately lose business and respect. That does not mean that we should use the mechanism of the state to transfer money from you to me, simply upon the theory that you must "pay the consequences" of your speech.
7.1.2009 4:28pm
SuperSkeptic (mail):
@ Ex-Fed. I guess what I am getting at is that the externalization of the costs associated with totally free speech is generally the rationale for limiting free speech. In particular, "under" the 1st amendment itself for clarity rather than through torts. I more or less would seek to internalize those costs (somehow).

Also, the "mechanism of the state" is used either way, whether your are limiting speech or compensating for tort injuries. Although, I do concur in what I sense are your anti-statist sentiments
7.1.2009 4:38pm
Ex-Fed (mail) (www):
SuperSkeptic: but the concept of internalizing costs is not consistent with the First Amendment, let alone with the concept of freedom of expression -- unless, of course, you apply First Amendment norms to the process of internalization.

A system in which you can force me to pay if I want to say something true about you that hurts you is tyrannical. It is precisely my point that the mechanism of the state is used either way. What I'm trying to say is that the concept "Allow people to freely enter the "marketplace of ideas" at their own risk" doesn't tell us anything unless you specify whether "at their own risk" is governed by First Amendment concepts.
7.1.2009 4:43pm
SuperSkeptic (mail):
@ Ex-Fed

I think your system of tyranny mischaracterizes my position. If you are a liar and I out it, truth was once a defense to libel and defamation, no? If you are not, then I really should be held accountable for that speech, if indeed a jury finds it is the proximate cause of your injuries, should I not?

Speech remains absolutely free (from congress and the courts) and costs fall upon the speaker. win-win really.

If you shout "fire" in the theater and a man is trampled by another, who would the jury likely find to be the proximate cause of the battery or what have you? the stampeder or you?
7.1.2009 5:24pm
Ex-Fed (mail) (www):
think your system of tyranny mischaracterizes my position. If you are a liar and I out it, truth was once a defense to libel and defamation, no? If you are not, then I really should be held accountable for that speech, if indeed a jury finds it is the proximate cause of your injuries, should I not?



If that's your position, then I'm not following how what you are advocating is different than what we have now.
7.1.2009 5:30pm
SuperSkeptic (mail):
The difference is in the "narrow exceptions" rules the post references. I say abolish them. There is no need for "clear and present danger" standards or delineating some speech as "inherently dangerous" or without benefit such that it may be "unprotected." I reject the notion of "unprotected" speech whole-heartedly.
7.1.2009 5:39pm
Ex-Fed (mail) (www):
The difference is in the "narrow exceptions" rules the post references. I say abolish them. There is no need for "clear and present danger" standards or delineating some speech as "inherently dangerous" or without benefit such that it may be "unprotected." I reject the notion of "unprotected" speech whole-heartedly.




But wait. You just said:

I think your system of tyranny mischaracterizes my position. If you are a liar and I out it, truth was once a defense to libel and defamation, no? If you are not, then I really should be held accountable for that speech, if indeed a jury finds it is the proximate cause of your injuries, should I not?



So you acknowledge, at least, the defamation exception to the First Amendment. It also appears that you acknowledge what is sometimes called the clear and present danger exception, based on your pay-for-the-consequences-of-shouting-fire hypothetical.

Are you simply talking about abandoning all criminal consequences in favor of civil consequences? Because that's different than saying you are changing the scheme of exceptions to the First Amendment.
7.1.2009 5:56pm
SuperSkeptic (mail):
I acknowledged defamation for the sake of argument, in an attempt to explicate myself, which was clearly unsuccessful, I apologize. In actuality, I would abolish defamation too - as a restriction on free speech. A true statement is a true statement, and a false statement is a false statement. No liability either way - in a perfect world. Such is the price of free speech in a free country. Egalitarian, no? (this I think, is the best place to critique my position because eliminating defamation can be unequitable and certainly externalizes costs from the defamer onto the "victim" or society as a whole, but I disgress).

As for the clear and present danger exception, I thought I disclaimed that pretty clearly as well as all the other judicially-crafted exceptions to the First Amendment. What I mean by "paying the consequences" (and this could be the source of our confusion) is not directly FOR the speech, but for the OTHER ACTIONS that are unlawful, i.e. the battery in the movie theater.

I am talking about abandoning statutory or pre-emptively designated criminal consequences for any speech, of course. Civil liability would remain, but not for the speech per se, but for any actions that cause an injury. I do not mean literally held accountable for the speech, but actions.

"The line between what is permissible and not subject to control and what may be made impermissible and subject to regulation is the line between ideas and overt acts." (J. Douglas, Concurring in Brandenburg v. Ohio)

While he conflates ideas and actions in the "fire"-movie-theater-scenario, I think they are capable of severance even there.

gotta run, hope that helps!
7.1.2009 6:48pm
Monty:
I agree with Black that "No Law" should be read litterially. That goes beyond just yelling 'fire' in a theater... The only line is: Is it speach.

No Law applies to:
Defamation
Clear and Present Danger
Obscenity
Incitement
Threats
Conspiracy Liability prior to a member's overt act
Time Place Manner restrictions

Probably missed something, but you get the idea, if you do nothing more then speak, no matter what you say, you cannot be tried or held liable.
7.1.2009 7:08pm
Eugene Volokh (www):
Monty: So when someone comes up to someone else on the street and says "Give me your money or I'll kill you," and the victim runs away (so that no money changes hands, and no gun is displayed), the speech is constitutionally protected, right? Likewise, if someone calls in a bomb threat to a building, the speech is constitutionally protected, yes?
7.1.2009 7:52pm
Monty:
The problem is that once some speech goes unprotected, it becomes possible to expand the area of unprotected speech to other acts that society frowns upon. The idea that people can make threats of both kinds is a real cost to such an absolutist position. But at the same time, we pay prices for many of our rights. The 4th, 5th, and 6th amendments certainly result in criminals going free, and impose costs on government, but we have decided that the protections they provide to the innocent are worth it. Likewise strengthening the protection of all speech is worth the cost that would come from threats.

However, I don't really know how it would apply to contracts, fraud or any other area where the speech is so important.
7.1.2009 8:29pm
VFBVFB (mail):
--- go ahead and yell "fire" at a movie theater, but be prepared to pay the consequences, in liability for injuries ---

One problem with this is that a substantial percentage of the population is judgment-proof. You cannot get from people what they do not have. (And sometimes you cannot get what they do have.)
7.1.2009 9:40pm
A. Zarkov (mail):
For some reason ADL has gotten cozy with the brown supremacist organization known as La Raza (The Race). From the ADL website:
As part of its ongoing efforts to partner with national Hispanic civil rights organizations, the Anti-Defamation League (ADL) participated in the 2008 National Council of La Raza (NCLR) annual conference,...
ADL and La Raza have attacked news anchorman Lou Dobbs or anyone else critical of unrestricted immigration calling such criticism "hate speech." See this transcript of Dobbs debating with Janet Murguia of the Council of La Raza.

If La Raza is so worried about hate speech then why did they honor José Ángel Gutiérrez in 1994 by giving him their "Chicano Hero Award?" In 1969 he said:
We have got to eliminate the gringo, and what I mean by that is if the worst comes to the worst, we have got to kill him.
Is that not hate speech or even worse? One also has to wonder why ADL wants to partner up with such an organization particularly when ADL's own press release reveals rampart anti-Semetism in the US Hispanic community-- particularly among Hispanic immigrants. The ADL survey found:
The [survey] findings in brief … Strongly anti-Semitic:

* 17% of Americans
* 35% of Hispanics
o 44% of foreign-born Hispanics
o 20% of Hispanic Americans born in U.S.
* 35% of African-Americans
* 3% of U.S. college and university student
Alan Potash's statements seem to fall right in line with La Raza's "hate speech is not free speech" meme. In short I don't believe his retraction is sincere. He said what he meant and he meant what he said.
7.2.2009 1:13am
interruptus:

So when someone comes up to someone else on the street and says "Give me your money or I'll kill you," and the victim runs away (so that no money changes hands, and no gun is displayed), the speech is constitutionally protected, right? Likewise, if someone calls in a bomb threat to a building, the speech is constitutionally protected, yes?

The first one at least seems like it could be prohibited without criminalizing the speech itself, by taking the verbal threat merely as evidence of an attempted crime rather than the crime itself. My impression is that soliciting murder is treated somewhat like this already: it's the fact of arranging (or attempting to arrange) for a hitman that's illegal, not any particular conversation that happens in that process.

Bomb threats are trickier, because in the case where the bomb threat is fake, it really is the speech itself that's causing a public disruption (if there actually were a bomb, the speech would of course be irrelevant, since the crime of interest would be planting the bomb). It seems like it might be vaguely related to libel, in being a category of harmful false speech.
7.2.2009 4:08am
David M. Nieporent (www):
Is that not hate speech or even worse? One also has to wonder why ADL wants to partner up with such an organization
Perhaps because that's a pretty ridiculous guilt-by-association? 40 years ago, when some really obscure law professor was in his 20s, he said something stupid. 25 years after that, he was given an award by an organization for something else. 13 years after that, the ADL participated in a conference run by this organization. Uh, yeah.
7.2.2009 11:42am
A. Zarkov (mail):
David M. Nieporent:

"Perhaps because that's a pretty ridiculous guilt-by-association? 40 years ago,..."

If Gutiérrez's 1969 statement was the end of it, I would agree with you. But the leopard really hasn't changed his spots. He has contained with his outrageous anti-American and anti-white statements. How about "Our devil has pale skin and blue eyes," or "To the gringos in the audience, I have one final message to convey, 'Up yours, baby. You've had it, from now on'" Last year I saw Gutiérrez in a TV interview and he was just as strident as ever.

As you can read in the CNN transcript La Raza is calling for the censorship of anyone who is critical of illegal immigration. The want Lou Dobbs taken off the air, and Pat Buchanan taken off the air to name but two. They want that now, not in 1969. So La Raza hasn't changed its spots either.

I also suppose you don't see anything contradictory about ADL partnering with an organization that wants to increase the number of anti-Semites in the US according to their own survey!

I guess you have some kind of statute of limitation for people who make these kind of remarks.
7.2.2009 1:12pm
David M. Nieporent (www):
If Gutiérrez's 1969 statement was the end of it, I would agree with you. But the leopard really hasn't changed his spots. He has contained with his outrageous anti-American and anti-white statements. How about "Our devil has pale skin and blue eyes," or "To the gringos in the audience, I have one final message to convey, 'Up yours, baby. You've had it, from now on'
There are no actual sources anywhere for any of those quotes that I can see; googling them just reveals mostly sites I wouldn't want in my browser history, and the tamer sites that I can find don't provide any source for the quotes at all.

Is there any reason to believe they're of any more recent provenance than the "eliminate the gringo" comment?
7.2.2009 2:14pm

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