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It felt really earnest, like a school project, Lorde says

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New York (1922) Gitlow was distributing a left-wing manifesto that called for socialism through strikes and class action Gitlow claimed that since there was no resulting action from the manifesto the statute was incorrect Outcome: The defendant was found guilty due to the possibility of danger to public security This shows that a state may forbid both speech and publication if it could result in action, such as riots, dangerous to public security Chaplinsky v