Frohwerk v. United States (1919)
Substantive Issue:
Can words of persuasion alone, with no agreed-upon means to obstruct
recruitment, constitute a conspiracy that violates the Espionage Act?
USSC Ruling:
Conviction affirmed 9-0; Holmes wrote the majority opinion.
Reasoning:
Words alone are sufficient to kindle a spark that might grow into a larger and
more dangerous fire.