Herndon v. Lowry
E615009
Herndon v. Lowry was a 1937 U.S. Supreme Court decision that overturned the conviction of a Black Communist organizer under Georgia’s insurrection statute, strengthening First Amendment protections for political advocacy.
All labels observed (1)
| Label | Occurrences |
|---|---|
| Herndon v. Lowry canonical | 1 |
How this entity was disambiguated
This entity first appeared as the object of triple T6737220 — 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: Herndon v. Lowry Context triple: [United States Supreme Court cases of the Hughes Court, includesCase, Herndon v. Lowry]
-
A.
Hurd v. Hodge
Hurd v. Hodge is a 1948 U.S. Supreme Court case that held racially restrictive covenants in property deeds could not be judicially enforced in the District of Columbia because such enforcement would violate the Fifth Amendment’s Due Process Clause.
-
B.
Henry v. Hodges
Henry v. Hodges is a federal court case challenging state bans on same-sex marriage, decided alongside other landmark marriage equality cases prior to Obergefell v. Hodges.
-
C.
Ware v. Hylton
Ware v. Hylton was a 1796 U.S. Supreme Court case that held federal treaties override conflicting state laws, helping to establish the authority of the national government under the Constitution.
-
D.
Lucas v. Earl
Lucas v. Earl is a landmark 1930 U.S. Supreme Court tax law case that established the principle that income is taxed to the person who earns it, regardless of contractual arrangements to split or assign that income.
-
E.
Argersinger v. Hamlin
Argersinger v. Hamlin is a 1972 U.S. Supreme Court case that extended the right to counsel to defendants in misdemeanor cases that may result in imprisonment.
- 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: Herndon v. Lowry Target entity description: Herndon v. Lowry was a 1937 U.S. Supreme Court decision that overturned the conviction of a Black Communist organizer under Georgia’s insurrection statute, strengthening First Amendment protections for political advocacy.
-
A.
Hurd v. Hodge
Hurd v. Hodge is a 1948 U.S. Supreme Court case that held racially restrictive covenants in property deeds could not be judicially enforced in the District of Columbia because such enforcement would violate the Fifth Amendment’s Due Process Clause.
-
B.
Henry v. Hodges
Henry v. Hodges is a federal court case challenging state bans on same-sex marriage, decided alongside other landmark marriage equality cases prior to Obergefell v. Hodges.
-
C.
Ware v. Hylton
Ware v. Hylton was a 1796 U.S. Supreme Court case that held federal treaties override conflicting state laws, helping to establish the authority of the national government under the Constitution.
-
D.
Lucas v. Earl
Lucas v. Earl is a landmark 1930 U.S. Supreme Court tax law case that established the principle that income is taxed to the person who earns it, regardless of contractual arrangements to split or assign that income.
-
E.
Argersinger v. Hamlin
Argersinger v. Hamlin is a 1972 U.S. Supreme Court case that extended the right to counsel to defendants in misdemeanor cases that may result in imprisonment.
- F. None of above. chosen
Statements (47)
| Predicate | Object |
|---|---|
| instanceOf |
U.S. Supreme Court case
ⓘ
criminal law case ⓘ |
| areaOfLaw |
civil liberties
ⓘ
constitutional law ⓘ criminal law ⓘ |
| citation |
301 U.S. 242
ⓘ
57 S. Ct. 732 ⓘ 81 L. Ed. 1066 ⓘ |
| constitutionalProvision |
First Amendment to the United States Constitution
NERFINISHED
ⓘ
Fourteenth Amendment to the United States Constitution NERFINISHED ⓘ |
| court | Supreme Court of the United States ⓘ |
| decisionDate | 1937-04-26 ⓘ |
| factSummary | Angelo Herndon was convicted in Georgia for possessing Communist literature and organizing Black and white workers, alleged to advocate insurrection. NERFINISHED ⓘ |
| geographicFocus | Fulton County, Georgia NERFINISHED ⓘ |
| holding |
Mere advocacy of abstract doctrine, without incitement to imminent lawless action, cannot be criminalized under the Georgia insurrection statute as applied.
ⓘ
The conviction of Angelo Herndon under Georgia’s insurrection statute violated constitutional protections for freedom of speech and due process. ⓘ |
| impact |
limited the use of broad insurrection and sedition statutes against political organizers
ⓘ
strengthened constitutional protection for radical and unpopular political speech ⓘ |
| jurisdiction |
United States of America
ⓘ
surface form:
United States
|
| languageOfProceedings | English ⓘ |
| legalIssue |
First Amendment freedom of speech
NERFINISHED
ⓘ
due process under the Fourteenth Amendment ⓘ political advocacy ⓘ |
| majorityOpinionBy | Justice Owen J. Roberts NERFINISHED ⓘ |
| outcome | conviction reversed ⓘ |
| partyAffiliationOfPetitioner | Communist Party USA NERFINISHED ⓘ |
| petitioner | Angelo Herndon NERFINISHED ⓘ |
| petitionerDescription | Black Communist organizer ⓘ |
| precedentFor |
expanded protection for political advocacy under the First Amendment
ⓘ
limits on state power to criminalize radical political speech ⓘ |
| proceduralPosture | review of a criminal conviction under a state insurrection statute ⓘ |
| relatedCase |
Brandenburg v. Ohio
NERFINISHED
ⓘ
Gitlow v. New York NERFINISHED ⓘ Whitney v. California NERFINISHED ⓘ |
| relatedConcept |
clear and present danger test
ⓘ
incitement standard ⓘ |
| respondent | Lowry NERFINISHED ⓘ |
| respondentRole | Fulton County, Georgia, law enforcement official ⓘ |
| state | Georgia ⓘ |
| stateLawInvolved | Georgia insurrection statute ⓘ |
| term | 1936 Term ⓘ |
| topic |
Communist Party activity
ⓘ
freedom of speech ⓘ political dissent ⓘ racial justice organizing ⓘ |
| vote | 5–4 ⓘ |
| yearDecided | 1937 ⓘ |
How these facts were elicited
The pipeline generated the facts above by prompting gpt-5.1 with this entity's name + description and the instruction below.
Instruction
You are a knowledge base construction expert. Given a subject entity and a description of it, return factual statements that you know for the subject as a JSON list of dictionaries(triples), where keys must be "subject", "predicate" and "object". The number of facts may be very high, between 25 to 50 or more, for very popular subjects. For less popular subjects, the number of facts can be very low, like 5 or 10. # Requirements - If you don't know the subject at all, return an empty list. - If the subject is not a named entity, return an empty list. - Include at least one triple where predicate is "instanceOf". - Do not get too wordy. - Separate several objects into multiple triples with one object.
Input
Subject: Herndon v. Lowry Description of subject: Herndon v. Lowry was a 1937 U.S. Supreme Court decision that overturned the conviction of a Black Communist organizer under Georgia’s insurrection statute, strengthening First Amendment protections for political advocacy.
Referenced by (1)
Full triples — surface form annotated when it differs from this entity's canonical label.