The year 1919 was buzzing with First Amendment cases. On March 10, 1919, the Supreme Court ruled in Frohwerk v. United States that the conviction of a newspaper editor under the Espionage Act of 1917 was constitutional. The publication, Missouri Staats-Zeitung, criticized the United States’ involvement in World War I. Justice Oliver Wendell Holmes wrote that the published articles were a “willful obstruction” on the country’s war recruitment efforts. While Jacob Frohwerk argued that he never intended to obstruct recruitment, the court ruled that “conspiracy to obstruct recruiting would be criminal even if no means were agreed upon specifically by which to accomplish the intent.”