Frohwerk v. United States

E55132

First Amendment case United States Supreme Court case criminal law case

Frohwerk v. United States is a 1919 U.S. Supreme Court case in which the Court upheld a conviction for antiwar newspaper articles, reinforcing broad federal power to punish speech deemed obstructive to World War I military recruitment.

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All labels observed (1)

Label	Occurrences
Frohwerk v. United States canonical	10

How this entity was disambiguated

This entity first appeared as the object of triple T439836 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.

NED1 Entity disambiguation (via context triple) gpt-5-mini-2025-08-07

Target entity: Frohwerk v. United States
Context triple: [Espionage Act of 1917, usedInCase, Frohwerk v. United States]

A. United States v. Darby
United States v. Darby is a 1941 U.S. Supreme Court case that upheld federal labor regulations under the Commerce Clause and marked a broad expansion of federal power over economic activity.
B. Reynolds v. United States
Reynolds v. United States is an 1879 U.S. Supreme Court case that established the distinction between protected religious belief and regulable religiously motivated conduct, holding that the Free Exercise Clause does not excuse individuals from compliance with otherwise valid criminal laws such as those banning polygamy.
C. United States v. Comstock
United States v. Comstock is a 2010 U.S. Supreme Court case that upheld Congress’s authority to civilly commit mentally ill, sexually dangerous federal prisoners beyond their release date under the Constitution’s Necessary and Proper Clause.
D. Printz v. United States
Printz v. United States is a 1997 U.S. Supreme Court decision that limited federal power by holding that Congress cannot compel state or local officials to implement federal regulatory programs.
E. Bolling v. Sharpe
Bolling v. Sharpe is a 1954 U.S. Supreme Court case that held racial segregation in Washington, D.C. public schools unconstitutional under the Fifth Amendment’s Due Process Clause.
F. None of above. chosen
G. Unsure - the case is ambiguous/there is not enough information to decide.

NED2 Entity disambiguation (via description) gpt-5-mini-2025-08-07

Target entity: Frohwerk v. United States
Target entity description: Frohwerk v. United States is a 1919 U.S. Supreme Court case in which the Court upheld a conviction for antiwar newspaper articles, reinforcing broad federal power to punish speech deemed obstructive to World War I military recruitment.

A. United States v. Darby
United States v. Darby is a 1941 U.S. Supreme Court case that upheld federal labor regulations under the Commerce Clause and marked a broad expansion of federal power over economic activity.
B. Reynolds v. United States
Reynolds v. United States is an 1879 U.S. Supreme Court case that established the distinction between protected religious belief and regulable religiously motivated conduct, holding that the Free Exercise Clause does not excuse individuals from compliance with otherwise valid criminal laws such as those banning polygamy.
C. United States v. Comstock
United States v. Comstock is a 2010 U.S. Supreme Court case that upheld Congress’s authority to civilly commit mentally ill, sexually dangerous federal prisoners beyond their release date under the Constitution’s Necessary and Proper Clause.
D. Printz v. United States
Printz v. United States is a 1997 U.S. Supreme Court decision that limited federal power by holding that Congress cannot compel state or local officials to implement federal regulatory programs.
E. Bolling v. Sharpe
Bolling v. Sharpe is a 1954 U.S. Supreme Court case that held racial segregation in Washington, D.C. public schools unconstitutional under the Fifth Amendment’s Due Process Clause.
F. None of above. chosen

Statements (47)

Predicate	Object
instanceOf	First Amendment case ⓘ United States Supreme Court case ⓘ criminal law case ⓘ
areaOfLaw	constitutional law ⓘ criminal law ⓘ freedom of expression ⓘ
authorOfMajorityOpinion	Oliver Wendell Holmes Jr. ⓘ
category	Espionage Act prosecution ⓘ United States free speech case ⓘ
citation	249 U.S. 204 ⓘ
constitutionalProvisionInvolved	First Amendment to the United States Constitution ⓘ freedom of speech clause ⓘ
country	United States of America ⓘ surface form: United States
courtMembership	White Court ⓘ
decisionDate	1919 ⓘ
decisionYear	1919 ⓘ
doctrine	clear and present danger test (early application) ⓘ
era	World War I era ⓘ
fullCaseName	Frohwerk v. United States self-link ⓘ
governmentActionChallenged	federal criminal prosecution for antiwar publications ⓘ
hasJurisdiction	Supreme Court of the United States ⓘ
historicalContext	World War I ⓘ
holding	The First Amendment did not bar prosecution of the defendant's antiwar publications under the circumstances of the case. ⓘ The Supreme Court held that the federal government could punish speech deemed to obstruct military recruitment during World War I. ⓘ The Supreme Court upheld the defendant's conviction for antiwar newspaper articles under the Espionage Act. ⓘ
impact	contributed to early restrictive interpretation of First Amendment free speech protections ⓘ reinforced broad federal power to punish wartime speech deemed obstructive to military recruitment ⓘ
languageOfCourt	English ⓘ
legalIssue	federal power to punish obstruction of military recruitment ⓘ freedom of speech ⓘ scope of First Amendment protections during wartime ⓘ
levelOfCourt	court of last resort ⓘ
opinionBy	Oliver Wendell Holmes Jr. ⓘ
pageInUnitedStatesReports	204 ⓘ
petitioner	Frohwerk ⓘ
precedentStatus	binding precedent in federal courts unless overruled or limited ⓘ
relatedCase	Abrams v. United States ⓘ Debs v. United States ⓘ Schenck v. United States ⓘ
respondent	United States of America ⓘ surface form: United States
result	conviction affirmed ⓘ
statuteInterpreted	Espionage Act of 1917 ⓘ
subjectMatter	antiwar newspaper articles ⓘ criticism of U.S. participation in World War I ⓘ
timePeriod	early 20th century ⓘ
unanimousDecision	true ⓘ
volumeInUnitedStatesReports	249 ⓘ

How these facts were elicited

Referenced by (10)

Full triples — surface form annotated when it differs from this entity's canonical label.

Espionage Act of 1917 → usedInCase → Frohwerk v. United States ⓘ

Frohwerk v. United States → fullCaseName → Frohwerk v. United States self-link ⓘ

Abrams v. United States → relatedCase → Frohwerk v. United States ⓘ

Debs v. United States → similarToCase → Frohwerk v. United States ⓘ

clear and present danger test → appliedInCase → Frohwerk v. United States ⓘ

Frohwerk → roleIn → Frohwerk v. United States ⓘ

Frohwerk → defendantIn → Frohwerk v. United States ⓘ

Frohwerk → hasNotableCourtCase → Frohwerk v. United States ⓘ

The First Amendment did not bar prosecution of the defendant's antiwar publications under the circumstances of the case. → isCentralHoldingOf → Frohwerk v. United States ⓘ

subject surface form: The First Amendment did not bar prosecution of the defendant's antiwar publications under the circumstances of the case

The First Amendment did not bar prosecution of the defendant's antiwar publications under the circumstances of the case. → relatedCase → Frohwerk v. United States ⓘ