Skokie, Illinois, Nazi march
In 1977, Skokie, Illinois, a suburb of Chicago with a significant population of Holocaust survivors, became the focal point of a controversial neo-Nazi march planned by Frank Collin, leader of the American National Socialist Party. The proposed rally prompted the village to enact several ordinances aimed at regulating public demonstrations, including requirements for permits, liability insurance, and restrictions on the display of militaristic uniforms. When Collin applied for a permit, his request was denied due to the inflammatory nature of the planned demonstration, leading to a legal battle over free speech rights.
This case gained national attention as it raised important questions about the balance between free expression and community safety. Supported by the American Civil Liberties Union, Collin contested the village's ordinances, and a federal court ultimately ruled in favor of the Nazis, emphasizing First Amendment protections. Although the Supreme Court declined to hear Skokie's appeal, the case highlighted unresolved tensions surrounding hate speech and the limits of free expression in a diverse society. The incident led to the establishment of the Illinois Holocaust Museum and Education Center, reflecting the community's response to this painful chapter in its history.
Subject Terms
Skokie, Illinois, Nazi march
Date: March, 1977-October 16, 1978
Place: Skokie and Chicago, Illinois
Significance: When members of the American Nazi Party attempted to march in a largely Jewish community, their right to free expression clashed with the community’s right to protect its members from ethnic and religious hatred
In March, 1977, Frank Collin, a leader of the American National Socialist Party, announced plans for the neo-Nazi organization to hold a rally before the Skokie Village Hall. A suburb of Chicago, Skokie had a large Jewish population, many of whom were survivors of the Holocaust in Europe. In order to prevent the controversial march, the village enacted three ordinances on May 2. The first required permits for parades and assemblies, and also required the applicants to purchase expensive liability insurance. The second prohibited dissemination of materials intended to incite racial or religious hatred. The third prohibited political leaders from participating in demonstrations in military-style uniforms.
On June 22, 1977, Collin applied for a permit under the ordinances, and after he made it clear that the demonstrators would wear Nazi-like uniforms complete with swastikas, the permit was denied. Supported by the American Civil Liberties Union, Collin then went to a federal district court and requested an injunction to prevent Skokie from enforcing its ordinances, with the argument that the ordinances violated the right to free expression as protected by the First Amendment.
In the resulting decision, Smith v. Collin (1978), the district court ruled in favor of the expressive rights of the Nazis. Based on the premise that the ordinances’ purpose was to shield people from offensive ideas, the court’s decision held that the concept of community standards of decency did not apply when the issue was content of political speech, and it emphasized that the Supreme Court in Tinker v. Des Moines Independent Community School District (1969) had established that any restriction on the “symbolic forms of expression” must be justified by compelling governmental interests, a test not met by Skokie. The decision was affirmed by court of appeals, and the Illinois Supreme Court issued a similar ruling. Although Collin and followers prevailed in these court decisions, they decided to hold their rallies in downtown Chicago on June 24 and July 9, 1978, and their small groups of demonstrators were shouted down by huge hostile audiences.
On October 16, 1978, the Supreme Court announced its refusal to hear Skokie’s appeal in Smith v. Collin, but Justice Harry Blackmun, joined by one other member of the Court, dissented and argued that the Court should consider the issues of the case. Blackmun noted that the Court had never formally overturned Beauharnais v. Illinois (1952), a case which had upheld criminal sanctions for defamation of groups based on race or religion; in addition, he observed that a Nazi march in Skokie might constitute a “potentially explosive and dangerous situation,” perhaps analogous to shouting fire in a crowded theater. Because seven members of the Court voted not to review the case, however, the Skokie controversy failed to resolve any of the difficult issues concerning “fighting words” and “hate speech.”