In cases such as Abrams v. United States, 250 U.S. 616 (1919) and Gitlow v. New York, 268 U.S. 652 (1925) and others, the United States Supreme Court struggled to draw the line between politically unpopular speech and actual threats to national security. Masses Publishing Co. v. Patten greatly influenced the Supreme Court's eventual adoption in Brandenburg v. Ohio of the "incitement test" for advocacy of illegal activity.
