In November 1919, eight months after Schenck and Debs were decided, the Court resolved Abrams v. United States. In this case, the defendants distributed leaflets that urged factory workers who made war munitions to go on strike. The federal government prosecuted them for violating the Espionage Act. The Supreme Court upheld their convictions by a 7-2 vote. Justice Clarke wrote the majority opinion. He found that this case was similar to Schenck and Debs: “The manifest purpose of such publications [the leaflets] was to create an attempt to defeat the war plans of the Government of the United States, by bringing upon the country the paralysis of a general strike, thereby arresting the production of all munitions and other things essential to the conduct of the war.”
In Abrams, Justices Holmes dissented, along with Justice Brandeis.