ABSTRACT
In Stromberg v. California, 283 US 359, an important turning point in the history of free speech, the US Supreme Court struck down a state law that made it illegal to display a red flag. Stromberg was the first time the Court extended the First Amendment to cover symbolic speech. The state law in Stromberg dated from 1919 when, in the immediate aftermath of the Bolshevik Revolution in Russia, fears about anarchism and communism ran high in the United States. The California state legislature made it illegal to display a "red flag" to express anarchist views, to incite sedition, or to serve as a symbol of "opposition to organized government." Stromberg was significant for two reasons. First, although it was a victory for free speech, the victory came on what one scholar called "ultra-technical" grounds. Second, Stromberg was the first time the Court recognized that speech encompassed symbols as well as words.
