[1] In 1966, several months after the Watts riots and in response to the killing of Leonard Deadwiler (a Black man shot by police while driving his pregnant wife to the hospital), John Harris, Jr., was arrested while handing out leaflets which said, among other things, "Wanted for the murder of Leonard Deadwiler, Bobo the cop.

He was joined in this action by Jim Dan and Diane Hirsch, members of the PLP, and Farrel Broslawsky, a history instructor.

In dissent, Justice Douglas noted, If the ‘advocacy’ which Harris used was an attempt at persuasion through the use of bullets, bombs, and arson, we would have a different case.

When criminal prosecutions can be leveled against them because they express unpopular views, the society of the dialogue is in danger.The doctrine was later extended to situations where the state is seeking to execute a civil fine against someone, or has jailed a person for contempt of court.

In regard to the exceptions which the Younger Court articulated, later decisions make it clear that these are highly difficult to meet.