This case's ruling was extended to a case that centered on Eugene Dennis, who petitioned for one cause alongside Benjamin J. Davis. A more protective standard was implemented following this case, which replaced the Hicklin test. Elizabeth Baer was originally tried alongside the plaintiff in this case, which paved the way for the ruling in Abrams v. United States. This case was largely overturned in (*) 1968 by Brandenburg v. (10[1])Ohio. This case's plaintiff distributed flyers noting that ■END■