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Clear and present danger
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===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''.<ref>Including cases such as ''Konigsberg v. State Bar of California'', 366 U.S. 36 (1961).<br/>Killian, pp 1101–1103.</ref> 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".<ref>''Brandenburg v. Ohio'', 395 U.S. 444 (1969).</ref><ref>Redish pp 104–106.<br/>Killian, pp 1109–1110.</ref> ''Brandenburg'' is now the standard applied by the Court to free speech issues related to advocacy of violence.<ref>E.g. in cases such as ''Hess v. Indiana'', 414 U.S. 105 (1973).<br/>Redish, p 105.<br/>Kemper, p 653.</ref>
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