Wikipedia:Peer review/Smith Act trials of Communist Party leaders/archive1

Smith Act trials of communist party leaders

This peer review discussion has been closed.
I've listed this article for peer review because I'm planning on nominating it for Featured Article status soon, and want it ship-shape before then. It would be best if the reviewer were someone familiar with FA criteria, and is willing to nitpick the prose. Also, it would be appreciated if the reviewer could comment on an open RfC inquiring about how detailed the legal material in the article should be. Thanks, Noleander (talk) 17:14, 21 March 2012 (UTC)

PS: There was a prior peer review at Wikipedia:Peer review/Foley Square trial/archive2 (the article has been renamed since then) but the article has been substantially improved since that review, so another review is warranted. --Noleander (talk) 20:40, 22 March 2012 (UTC)

Here's part 1 of my review, part 2 will follow likely later this weekend depending on how busy I am with other things. My major concern with the article is that it seems to accept as a historical fact that there seems to be a fairly strong pro-defense viewpoint in the article without sufficient balance from those who to whatever extent defend the trial or believe that the threat of communism in the late 1940s and early 1950s was real, or at least the US was justified in treating it as real. I suggest that efforts be made to provide balancing viewpoints. Aside from that it is quite good and while I suspect it needs some cleanup and a close check for MOS compliance, it should do fine at FAC in due course.

Specific things:

Lede

• It is only necessary to reference within the lede if it is not supported elsewhere in the article. [Done - Noleander]
• Shouldn't "Communist Party" be capped in the title of the article? [Done - Noleander]
• I would keep McCarthy out of the lede. That's basically saying that the prosecutions were unjustified by more or less calling them McCarthyism. Remember, that's a loaded term today. [Done - changed to Cold War - Noleander]
• "radical restructuring"? That makes it sound like they wanted to eliminate the department of Agriculture or something. You might do better to eliminate the second sentence of the lede entirely. [Done - Noleander]
• I would state the years of the two SCOTUS cases in parens after you name them. [Done - Noleander]
• I would avoid the bolding in the second paragraph. [Done - Noleander]
• Did those who sought the defendants' conviction also demonstrate? If they did, you should mention both. [No sources yet on this yet. More research needed. - Noleander] [I've looked through several sources, and they only mention demonstrations by supporters of the communist defendants. The only mention I can find of counter-protests is the anti-communists who were involved in the Peekskill riots. Those latter disturbances are mentioned in the article already, but that was not located at the courthouse, of course. - Noleander]
• Perhaps end the lede something like "could only prosecuted for their actions, not their beliefs." That way, you avoid the italics. [Done - Noleander]

Background

• "Red Scare". I would put this in text, but very cautiously because the term's somewhat POV. Putting it in a hatnote gives a term which not all would use too much prominence. As the Cold War certainly influenced American views of communists, I would put that in text too. You might want to look at Jonathan Bell's book The Liberal State on Trial, which really deals with the political aspects of this. [Done - Noleander]
• At some point in this background section, more needs to be said about the Soviet takeover of Eastern Europe, which certainly affected American views of communists. I would avoid the use of the word "appeasement"and perhaps more explicitly discuss the Yalta agreement. [Done - Noleander]
• Were the people convicted under the Smith Act convicted because of failure to register or membership in some organization? Isn't this inconsistent with the government suspending its campaign for the duration? [The only persons convicted under the Smith Act during WW II were American Nazis, not Communist party members. I'll ensure the article clearly conveys that. Noleander]
• The DOJ and FBI sound rather unreasonable and unthinking in "resuming their campaign". Maybe that's about the time you should mention Eastern Europe. [Done - Noleander]
• " they would later regret" Wouldn't more standard American usage be "it" or possibly "its members"? [Done - Noleander]
• Reasons why the US became more suspicious of communists are mentioned in three consecutive sections. Consolidate. [Done - Noleander]
• "the Republican Party"? Really? Just the Republican Party? The Dems said many similar things. Even liberals. McCarran and Wood were Democrats, you know! [Done Removed mention of Rep party - Noleander]

1949 trial

• "Despite the relatively small size of the CPUSA," delete. You've given the numbers, you should avoid characterizing them in this way. [Done - Noleander]
• "embarked on a campaign" This language suggests an assault or similar and should be avoided "sought to prosecute" is probably more neutral. [Done - Noleander]
• "Hollywood ten". Capitalize ten. [Done - Noleander]
• It probably isn't necessary to call Foster a hardliner a second time. [Done - Noleander]
• Why would waiting until the 1948 Democratic National Convention matter to liberal voters? They wouldn't vote until November. If there were fears about delegates, perhaps state it in terms of Truman's renomination. [Done - removed the sentence re the Dem Convention. - Noleander]
• The focus on domestic events without regard to international ones makes it seem that the government was acting in an irrational manner. [TBS: more work needed here - Noleander]

The article now has 3 paragraphs that give the reader a good understanding of external events that led to anti-communist feelings in the US:

• Section "Communist Party" … added entire paragraph about intenational events (incl Yalta & its consequences) that led to increased fear of communism within US.
• Section "Events outside the courtroom" - mentions USSR atomic bomb & Chinese civil war
• Section "Legal appeals of 1949 trial" - added entire new paragraph on international events 1950 to 1954, including First Indochina War, Rosenbergs, hydrogen bomb, & Korean war.

I think it now gives the reader the necessary context. But perhaps more is needed? A fresh pair of eyes (not mine :-) need to review the article for this issue one more time. --Noleander (talk) 01:49, 28 March 2012 (UTC)

• "level charges". I question the need for this phrase. Perhaps "bring charges", if you week to vary from the word "prosecute". [Done - Noleander]

• Rather than "organization", perhaps abbreviate and say CPUSA. Note that I see that you are doing it alphabetically but there may be confusion on the ones who follow Potash that they were CPUSA, not Furrier's Union. [Done - Noleander]
• "he professed to be unaffected and said" I would simply write "he stated" or similar. Saying that someone professes to do something implies doubt about their sincerity or veracity. [Done - Noleander]
• " because the federal grand jury (which approved the indictments) was composed of wealthy, propertied persons, rather than a broad cross-section of the community (at the time, grand jury members had to meet a minimum property test, and were paid only $4 per day)." Perhaps "because at that time, a potential grand juror had to meet a minimum property requirement, effectively eliminating the less affluent from service". [Done - Noleander]
• "who had been a judge for only 18 months" This seems to call into question whether he was competent to preside over such a trial. I would argue that he had been a judge for longer than Warren had been at the time of Brown. I would omit entirely except if you want to inline attribute.

Done - Removed "only" so it now reads ".... who had been a judge for 18 months when the trial began." The sources do mention this several times; and I read it not so much a statement about his quality, but rather "the lead judges stuck the new guy with the problematic trial". --Noleander (talk) 19:36, 26 March 2012 (UTC)

• Did they really spell "Adolf" as "Adolph"? If they did, I would put a [sic] next to it as a non-standard spelling in this context. [Done - No, that was my misspelling. Noleander]
• Isn't the fact that the Hiss trials were going on more or less simultaneous worth a mention? In the same courthouse? [Still TBD] [Done - Noleander]
• The characterization of the prosecution evidence in the lede led to surprise when I discovered here that the informant gave live testimony testifying to the intent of the CPUSA. This was presumably more than mere interpretation of Marx and Engels. Perhaps that reference in the lede should be rewritten, and perhaps also you might revisit this section. Right now it leaves one with the reference that almost all of the prosecution case was someone saying that page 117 of this book means such and such and page 119 another thing. "She also testified that the CPUSA espoused violent revolution against the government and that the CPUSA had attempted to recruit members working in key war industries, on instructions from Moscow" argues that this was not so. [Done - Noleander]
• Regarding the IWW, you might want to throw a pipe in here. Forgive me for being self-promotional. [Done - Noleander] If you are going to say they were arrested, you should also note that the vast majority were convicted. [Done - Noleander]
• "The opinion of contemporary media was overwhelming in favor of conviction, but an editorial in the left-leaning The New Republic, written after the prosecution rested on May 19, 1949, wrote that the government had "failed to make out the overwhelming case that many people anticipated before the trial began".[36] Legal scholar Michal Belknap wrote in 1981 that the prosecution case "just did not add up to much".[37]" I think you are guiding the reader too strongly here with these quotes. You might want to reserve such characterizations for a more analytical section which could give the arguments on both sides. Definitely the prosecution's case was weak, but Belknap writes from the perspective of a civil libertarian, according to the review of his 1977 book I downloaded from JSTOR (if you email me, I will send it to you). [Done - Noleander]
• "First, portraying the CPUSA as a conventional political party" There seems to be a grammatical problem here. Perhaps "First, they sought to portray ..." [Done - Noleander]
• "labor defense" Twice in quotation marks. [Done - Noleander]
• I suggest breaking up the defense section into smaller paragraphs. [Done - Noleander]
• "judge Medina" Judge. [Done - Noleander]
• Have any legal scholars taken the view that Medina presided over the trial fairly? It strikes me that this is a matter about which not all legal scholars would agree. It might be worth mentioning that Medina defended alleged traitors as a trial lawyer during World War II. Have you looked at his obits for when he died in 1990 to see if there are contrasting views? I saw an "appreciation" by a lawyer who knew him in the Columbia Law Review? [ TBS ... will return to this; more research needed] [Done - Added balancing material that presents Medina as fair. Removed some of the negative material. - Noleander].

Events outside the courtroom.

• Consider moving this section up, to allow the reader to have the context of the trial before the trial. [Done - Noleander]
• "government employee Alger Hiss was accused of being a communist" At that time, he had not been a government employee for several years. And he was convicted, after being tried for perjury. I do not ask you to get into that can of worms, but you should be accurate. [Done - But because that paragraph is describing events that transpired during the 1949 Smith Act trial, the emphasis remains on the first perjury trial of Hiss (hung jury), which was in 1949. The later conviction of Hiss was after the Smith Act trial. Noleander]
• I think you are giving too much space to the Peekskill Riot in comparison to other events. Consider trimming. [Done - Noleander]

More later. Good work.--Wehwalt (talk) 14:31, 24 March 2012 (UTC)

Thank you so much for the thoughtful and detailed comments. I'll be out of town, without computer access for the next couple of days, but as soon as I return, I'll start fixing these issues. Regarding the "pro defense" bias: I agree that is a concern, and I'll see what kind of balancing material I can dig up. Most of the modern sources do lean towards the defense in their analyses (as part of a general viewpoint that McCarthyism was not a good thing). It is easy to find sources from the 1950s and 1960s that say that the prosecution was doing the right thing. But I'll redouble my efforts and see if I can find some modern secondary sources that, at least, explain the motivation/rationale of the FBI & Dept of Justice. Thanks again. --Noleander (talk) 16:18, 24 March 2012 (UTC)

That sounds like a wise course. Obviously do not use obsolete sources. We can all agree that McCarthyism was a bad thing as a historical view, and yet write dispassionately about it. If you send me an email I will send you those sources I mentioned. I can't attach anything if I just email you.--Wehwalt (talk) 16:24, 24 March 2012 (UTC)

Email has been sent. I'm heading out the door now, so I won't be able to reply here or on email for next couple of days. Cheers. --Noleander (talk) 16:37, 24 March 2012 (UTC)

Hope you are enjoying your time away. Here's the rest of my review:

Convictions and sentencing

• Is there context that the judge's instructions can be put in? Were they based on the language of the Smith Act or was the judge making it up as he went along? To a 21st century audience, obviously the judge is going to be seen as unreasonable; a more nuanced approach may be appropriate. [TBS ... will come back to this one] [Done - Re-worded the jury instruction sentence so it does not make the judge sound insensible - Noleander]
• I would suggest that the reference to the future congressman be moved to someplace else. It doesn't seem terribly relevant to the contempt. [Done - moved to the "after prison" paragraph. - Noleander] Are hearings required to be held for summary contempt? [That is described in a bit more details in the article in the "Sacher v. United States" section. Judges, like Medina, can issue jail sentences to anyone in the courtroom without a hearing, provided they witnessed the transgressions themselves. I'll try to make that clearer in the text. - Noleander]

Aftermath

• It sounds like only Hoover and Republicans supported anti-communism. Surely this was not so? (see comment in earlier section) [I think this is okay now: (1) the reference to Republican Party has been removed from the article; (2) the sources are making the valid point that Hoover personally had a lot of say in whether or not the DOJ went forward with additional prosecutions after the initial trial; and (3) I'll be adding some more balancing material soon that sheds light on why the US (government and media) were so worried about the Communists. Noleander]
• "Subsequent high-profile hearings involving alleged communists included the 1950 trial of Alger Hiss" No, Hiss was found guilty (on retrial) in January 1950; both his trials started in 1949 and the hearings which prompted his perjury prosecutions were in 1948. In fact, he was being tried a floor up from the Smith Act defendants. [Done - Improved wording to indicate that he was convicted in 1950. The point of those sentences is to show that, after the conclusion of the 1949 trial, there were other, similar "anti communist" trials. - Noleander]
• If Gus Hall had the highest visibility among the defendants, he probably should have been mentioned already. [Done - Noleander]

Legal appeals

• I question the choice of the hatnote. I think it puts too much stress on the First Amendment claim. Putting it there is telling the reader in editorial voice that the defendants should be associated with the First Amendment, which of course everyone's for. Put it as a see also, I would. [Two other editors last month recommended very strongly that this article should contain more material about the legal issues, specifically the constitutional issues raised on appeal. I think all the legal scholars squarely characterize Dennis and Yates as "first amendment cases". I'm reluctant to remove any of the recently added legal/constitutional material since the other editors pushed so hard, and I don't want to backslide on that cooperation. The current link is already a mere "see also" link, not a "main" link, so it is not too emphatic. - Noleander]
• Given Judge (again the caps!) Hand's prominence, it would be useful to have more from his opinion. [Done - Added three key (but small) quotes from his opinion. - Noleander]
• The Korean War is only worth mentioning conversationally? Didn't it contribute to the negative perception of communists and lead to the passage (over Truman's veto in a Democrat-controlled Congress) of McCarran-Wood? [Done - Added an entire paragraph on Cold Ware developments in during the appeals process. - Noleander]
• "The Supreme Court limited its decision " If you are saying that it only granted cert on that issue, I would say "consideration", not "decision". [Done - Noleander]
• Given that you devote considerably more space to the dissent than to the majority, and don't even let Vinson complete his sentence, I think there's a tone issue here too. [Done - Added more detail from Vinson's opinion. - Noleander]
• I think your use of the term "rationalize" is could be taken as POV. Rationalization (making excuses) [Done - Noleander]

Second tier and following

• Where does the term green light come from? You should either inline attribute or avoid the quotation. [Done - The "green light" phrase was attributed in the footnote; but I've reworded the sentence to remove it. - Noleander]
• Regarding Khrushchev, you should probably pipe "revealed" to Secret Speech. [Done - Noleander]
• I question your choice to quote extensively from a concurring opinion (for which Black only spoke for himself and anyone who joined him) and relegate Harlan's majority opinion to a single sentence without a quote. Black probably makes for spicier reading, but that's not the court's opinion. Also, by blockquoting it, you are giving it additional impact. In the cases where there were dissents, a fair comment (that is, not a comment that will make the justice sound extreme) should be included. [Done - Removed quote & pic of concurring Black, and replaced with quote & pic of majority-writer Harlan. - Noleander]
• Again, in Noto you are choosing to emphasize the (spicier) concurring opinions, while giving short shrift both to the majority view and any other concurring opinions. Black and Douglas were fairly to one side of the spectrum when it came to the First Amendment. By only quoting them, you're not giving the reader a full view. [Done - Added larger quote from majority opinion - Noleander]
• In the last sentences of the article, you mention indictments and total years sentenced to, but fail to mention convictions. [The sources do not state the number of convictions. They only recite the number of indictments. I believe that is because the indictments were easier to find and count; whereas the convictions were harder to identify, particularly because so many cases were appealed. That is, there is an ambiguity about counting convictions: if the lower court convicts, then it is reversed on appeal, does that count as a conviction? - Noleander]

Then I would avoid connecting the two facts, because it's an apples and oranges situation. And did the sentences count if it was reversed on appeal? Does it mention total jail time served?--Wehwalt (talk) 14:13, 27 March 2012 (UTC)

I was not able to find a statistic on cumulative jail time served, but I was able to improve it to: "When the trials came to an end in 1958, 138 persons had been indicted, resulting in approximately 120 convictions with cumulative sentences totaling 418 years and $435,500 in fines." --Noleander (talk) 15:18, 27 March 2012 (UTC)

That sounds good.--Wehwalt (talk) 15:25, 27 March 2012 (UTC)

• I gather the Smith Act remains on the books? You should say so if so. [Done - Noleander]

General comment: It's generally quite good, and despite my comments, which I hope you don't consider harsh, with some cleanup it should do fine. I don't think there's any real question that there was an overreaction to the communist threat. But I think that if you state it dispassionately, giving equal time and tone (and equal opportunity to have the last word, for example), the reader can make his own judgment, and it probably won't be too different from yours, actually. But you should work to address the tone issue.--Wehwalt (talk) 11:10, 26 March 2012 (UTC)

Thanks for these additional comments. I'll start working on all these now, top to bottom. After fixing the straightforward issues, I'll turn my attention to focusing on the balance/POV issue: removing some material, and hunting for more sources that provide more explanation of the prosecution viewpoint. PS: I received the email and will use those sources. Cheers. --Noleander (talk) 18:29, 26 March 2012 (UTC)

I looked at contemporary news coverage and it does look like if there were anti-communist protests, they didn't make the papers, whereas the ones supporting the defendants were mentioned prominently. Your changes to date have been quite good.--Wehwalt (talk) 15:50, 27 March 2012 (UTC)

Communist Party in the title, maybe that should be capitalized.--Wehwalt (talk) 17:28, 27 March 2012 (UTC)

I renamed the article so Communist Party is now capitalized. The text in the lede was also changed accordingly. I think the capitalization is good now for Judge & Party throughout the article. --Noleander (talk) 19:10, 27 March 2012 (UTC)

OK, let me know when you are ready for me to take another run through.--Wehwalt (talk) 19:17, 27 March 2012 (UTC)

Thanks. It will probably be another 2 or 3 days. If you could comment on the Talk page issue Talk:Smith_Act_trials_of_communist_party_leaders#More_on_other_trials, that would be helpful, since that impacts the entire article. --Noleander (talk) 19:26, 27 March 2012 (UTC)

I've finished implementing all of the specific suggestions enumerated above. I'm now starting to make a top-to-bottom pass through the article focusing on neutrality and ensuring that the international context (explaining anti-communism) is properly presented. --Noleander (talk) 02:07, 28 March 2012 (UTC)

Wehwalt: I've finished my second pass through the article: I added more balancing material (explaining anti-communist attitudes); removed quite a bit of pro-defense POV material; and re-organized the sections in a more sensible fashion. Do you have time to scan the article one more time and see if I've overlooked anything or if the article appears unbalanced in any way? Thanks. --Noleander (talk) 21:28, 28 March 2012 (UTC)

Arbitrary break

Lede

• A brief statement of what the Smith Act did would not go amiss in the early part of the lede. [Done - Noleander]
• You use the word "trial" five times in the first two sentences of the second paragraph; seven times in the first three. Cut back on them. [Done - Noleander]
• The second sentence of the third paragraphs should probably be divided or rephrased "and" "and". [Done - Noleander]

Background

• Subsections consisting of a short paragraph should probably be combined. [Done - Noleander]
• The word "numerous" can probably safely be omitted. [Done - Noleander]
• Does the source say why the WWII case was not retried? [The source Encyclopedia of Right-Wing Extremism In Modern American History suggests a few reasons: (1) WW II was drawing to a close; (2) case was very difficult to prosecute; and (3) not certain of a guilty verdict. Let me know if you think that kind of detail should go into this article ... also, that detail is not yet in the Smith Act article which covers the 1943 trial. - Noleander]
• Placing the WWII midst bit where it is implies a connection. Probably there was, but I doubt if you want to spend the time discussing it. It might be wise to move the WWII to the passage of the Smith Act (on the eve of WWII or something like that). Note that the link is presently on the the second reference to WWII. You can probably get away with, say: [Done - Removed "midst" since it implies too much; fixed WW II link. Noleander]
• I would suggest changing "an ally in World War II" to "then an ally". [Done - Noleander]
• You are calling Foster a "hardline Stalinist" with editorial voice, but then allowing him to characterize Browder. There's a bit of a false comparison there, and also Foster's view may be colored somewhat. Suggest describing Browder yourself rather than letting Foster do it. [Done - Noleander]
• The mention of the US being allied with the USSR seems redundant; you've already established that. [Done - Noleander]
• "revelations of past instances of communist espionage in the US during 1930s and 1940s." I would strike the word "past", which may get you into debates you don't relish. [Done - Noleander] Also, the word "the" is missing near the end of the sentence. [Done - Noleander]

1949 trial

• The first sentence can be deleted. The next sentence is a perfectly fine way to begin, and I think if you'll look, you'll see you don't lose anything [Done - Noleander]
• "Also in 1948," Suggest, "The same year" or similar. Close proximity to another 1948. [Done - Noleander]

Start of the trial

• "a judge" suggest "on the bench". [Done - Noleander]
• I find it interesting the defts did not have to show up for court until March. You might want to mention their bail status. [ TBS ... thinking about where to put that out-on-bail info - Noleander]
• "Magazines, newspapers ..." This sentence is a bit problematic, stories are not a publication and cannot be included in the manner you do. [Done - Noleander] You might also want to say who "The Little Comissar" referred to. [Done - Noleander]
• The word "courthouse" occurs in three consecutive sentences ending with the congressional response. Perhaps the officers were assigned to "Foley Square"? [Done - Was able to eliminate one with " officers were assigned to the site", the other 2 seem essential. - Noleander]
• "Before the 1949 trial began, supporters of the defendants hoped to gain an advantage by letter-writing and by public demonstrations:" Perhaps, "Before the trial began, supporters of the defendant decided on a campaign of letter-writing and demonstrations." The word "public" seems redundant. Since you've already mentioned the demonstrators, I would add this seems a bit out of order. [Done - Noleander]

• "aggressive defense tactics". Out of order chronologically. [Done - Noleander]

• ""Although twelve CPUSA members were indicted, only eleven were tried, because William Z. Foster was not brought to trial due to his ill health." unsourced. Suggest deleting as Foster's health and the reason he was not tried are covered in the laundry list of defendants. [Done - Noleander]

Events outside

• I would not use the term Red Scare so boldly here. Perhaps "anti-communism (or, as some termed it, a Red Scare}" [Done - used anti-communism - Noleander]
• "a trial held in the same building as the 1949 Smith Act trial – the Foley Square courthouse" How about "a trial also held at the Foley Square courthouse". [Done - Noleander]
• "Chinese Communist party " Probably needs a cap. [Done - Noleander]
• You may want to say up front which defts were involved in the Peekskill riots, rather than making the reader dig. [Done - Noleander]
• "of communist defendants, including the 1949 trial defendants" Too many defendants. [Done - Noleander] Same with concerts in the next sentence. [Done - Noleander]
• "were also personally guilty " Strike "also personally" [Done - Noleander]
• "could never provide a fair outcome to" Maybe "could never produce a fair outcome for" [Done - Noleander]
• "1935 Seventh World Congress of the Comintern, when the CPUSA rejected violence as a means of change." Perhaps rather than "when", put "after which" [Done - Noleander]
• You use both "materials" and "material" close to each other. Watch the verb tenses if you change one. [Done - Noleander]
• Probably the matter about the labor strategy should be placed with the other material about how they tried to influence public opinion, demonstrations etc. [TBS: Need to think about this one. "Labor defense" was a broad umbrella; under it was (1) demonstrations outside the courthouse; (2) telegrams and letter writing; (3) claims of fundamental unfairness & class oppression; and (4) antagonizing the judge during the trial. I'll see if I can improve the text to make it clearer. - Noleander]
• " and that the they deliberately disrupted the trial " Perhaps "and that they deliberately were attempting to disrupt the trial". [Done - Noleander]
• "pretrial activity" Probably not a legal term. [Done - Noleander]
• If the judge who died hearing a Smith Act case was the one who died during WWII mentioned earlier, connect it up. If not, make it clear. [Done - He was the same. - Noleander]
• "as well as contemporary media," Awkward. [Done - changed to "The opinion of the American public and the news media was .." - Noleander]
• You might want to mention that in addition to the defense attorneys, Dennis was also sentenced for contempt. [Done - that was in the footnote; but I've moved it up to the text. - Noleander]
• It would be worthwhile to know if Medina allowed them bail, or if they had to run to the Second Circuit. [I'll look through the sources again, but I don't recall any of them specifying when/how the defendants were permitted to get out on bail. It must have been early, because no source says "they went to jail" or "they were led away in handcuffs". - Noleander] Also, released is not the word I'd use. Maybe "allowed bail"? [Done - I reworded to "During the appeal process, the defendants were not in prison because they posted bail after sentencing" - Noleander]

Appeals

• "Korean war" should be a capped W. [Done - Noleander] You should probably give the full name of the court, United States Court of Appeals for the Second Circuit, but you can pipe for brevity. [Done - Noleander] Did you ever mention the court they were tried in, the United States District Court for the Southern District of New York? Again, that can be piped and should be in an earlier section. [Done - Noleander]
• "judge Learned Hand". Judge Learned Hand [Done - Noleander]
• You might want to mention the date the 2nd Circuit came out with its opinion. [Done - Aug 1, 1950. Noleander]
• "appealed the federal Appeals Court" Very appealing. Perhaps "appealed the Second Circuit's decision" ... [Done - Noleander]
• You should clearly mention that Justice Douglas's opinion was a dissent when mentioning it in the quote box. [Done - Noleander]
• Justice Robert Jackson? [Done - Noleander]

Second tier

• " So when the " Too informal. [Done - Noleander]
• Some sort of mention of who Dorothy Healey was is needed. The image isn't a substitute for that. [Done - Also did 2 other named persons. - Noleander]
• "hear an appeal." Hear their appeals. [Done - Noleander]
• I'm not sure your use of spaced dashes in the article (here and elsewhere in it) is proper. Have you checked WP:DASH? [Done - Changed those dashes to commas; but DASH does permit spaced n-dashes in lieu of commas. I like mixing them up, to vary things. - Noleander].
• I appreciate what you are trying to do in not using "attorney" or "lawyer" too much. You can also use "counsel", i.e. "appoint unwilling counsel" [Done - Noleander]

Aftermath

• "has not been repealed". Perhaps "remains on the statute books" You are sort of saying it ought to be, as it is now. [Done - Noleander]
• "and ran for president of the US four times from 1972 to 1984, twice with Angela Davis as his vice presidential partner" I would delete "of the US" and put "running mate" for "vice presidential partner". [Done - Noleander]

That's about it. Good work, much better than it was. [preceding from user Wehwalt]

Roger that. I'll start implementing these improvements later today. Thanks again. --Noleander (talk) 15:15, 29 March 2012 (UTC)