Breaking the White Circle: How the Press and Courts Quieted a Chicago Hate Group, 1949–1952

Abstract

abstract Joseph Beauharnais’s story illustrates the dilemma created in cases of hate speech. The government and courts of Illinois decided that in Beauharnais’s case, it should not be protected. In a legal proceeding that has been cited more than three hundred times, just more than half of the US Supreme Court justices agreed with this verdict. After reviewing the societal and legal environments in which this story occurred, this article examines Beauharnais’s White Circle League literature, the means Chicago’s press and other organizations used to counter it, the legal ramifications of Beauharnais’s rhetoric, and the aftermath of the Supreme Court’s ruling. The authors supplemented resources from a substantial FBI file with additional government documents, newspaper articles, and court cases. This research reveals that many in Illinois—and some Supreme Court justices—considered the racist nature of Beauharnais’s expression intolerable. Furthermore, the study demonstrates the role of Chicago’s alternative press in shutting down the White Circle League.