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The New Deal in the Suburbs: A History of the Greenbelt Towns

area of expression, and would rely exclusively on them to prohibit abuses attending the freedom of speech. Besides the fact, however, that this formula might permit the frustration of federal policy in states willing to tolerate incitements to resistance against enforcement of that policy, anyone familiar with the history of the adoption and enforcement of sedition, anarchy, and anti-Communist legislation by the states in this century would probably not be willing to substitute for the existing federal constitutional barrier the possibility that Congress might legislate against such laws—as Professor Anastaplo suggests—through the power to guarantee a republican form of government to the states. The understanding of the Supreme Court regarding the meaning of the First Amendment and the necessity for judicial enforcement of its provisions has grown considerably since the abuses of the "clear and present danger" test perpetrated in Schenck and Dennis. (The test Holmes advocated in his Abrams and Gitlow dissents was entirely different from the test he announced in Schenck.) If all Professor Anastaplo seeks by his call for "absolutism" is a constitutional rule that no person can be held liable to a congressionally imposed penalty merely for expressing his political or religious beliefs, no matter how heretical, outrageous, or potentially dangerous those beliefs may appear to be, that position is now accepted by every member of the Supreme Court, even in the postWarren era. Of course, frightened judges may once again find a clear and present danger where none exists. But the same frightened judges could also distort the Anastaplo test by manipulating the concept of political speech. If, as Professor Anastaplo would have it, speech broadcast over television loses its political character, why could it not also be held that it loses its political character when uttered in a situation of grave danger? Professor Anastaplo states that he knows of no one who agrees with his position on the First Amendment. It is unlikely that he will have to change that assessment as the result of this book. DEAN ALFANGE, JR. University of Massachusetts