Part 2 of 2THE CRISIS WITHIN THE ACLUThe ACLU's decision to defend Chicago Nazi leader Frank Collin resulted in the most serious crisis in the organization's history, a crisis from which, some believe, it may never recover. 36 ACLU officials indicate that 40,000 members, out of a total membership of 250,000, resigned from the organization in 1977. In 1978 there were additional heavy membership losses. The resulting financial pinch led to a 15 per cent cut in the national ACLU staff, and a corresponding cut on the local level.
Not surprisingly, the loss of membership and income was most dramatic in the Chicago area. David Hamlin, executive director of the ACLU's Illinois affiliate, stated in August 1977: "We've projected that we'll lose 25 per cent of our Illinois membership and our financial support because of this Nazi-Skokie case." It is safe to assume that the majority of those resigning from the ACLU were Jews. 37
During 1977 and 1978, ACLU staff officials made a concerted effort to broaden support for their position on Skokie within the Jewish community. Executive Director Aryeh Neier, while freely admitting his lack of involvement in Jewish affairs, spoke with pride of his Jewish background and reminded audiences that he and his parents had been refugees from the Nazis. National Chairman Norman Dorsen, a Jewish professor of law at New York University, presented the ACLU case to the Domestic Affairs Commission of the American Jewish Committee. Neier, Dorsen and other ACLU leaders indicated that the angry Jewish response to the ACLU role in Skokie took them by surprise, since the organization had a long-standing policy of defending freedom of speech for Nazis.
Why did Jews, both within and outside the organization, react so strongly to the ACLU role in Skokie? Certainly the crucial factor was the burgeoning Holocaust consciousness of American Jews; the feeling that, no matter what, Nazism must never again be permitted to lift its head. At the same time, Jewish anger over the ACLU defense of the Nazis has to be seen in the context of a growing Jewish disillusionment with the general drift of the organization's policies.
Until the early 1960's the ACLU was a relatively small (45,000 members) organization, heavily concentrated in New York and devoted primarily to filing amicae curiae briefs in free speech and other First Amendment cases. Since that time, however, the Union has been transformed into a "mass organization with a large professional staff, involved in a wide range of concerns, of which fundamental civil liberties issues such as free speech and free assembly are only a small part."38 It was the Vietnam war that first thrust the organization into the political and social arena. When Dr. Benjamin Spock was indicted for counseling draft evasion, the national ACLU Board agreed to take the case, although a number of members voiced concern that such a step would result in the organization's defending Spock's politics, rather than his civil liberties. In 1970 Aryeh Neier was elected executive director as the "candidate of the left"; he was responsible for pushing the organization in a more political direction.39 Following the Cambodian invasion and the Kent State incident the ACLU, under Neier's direction, passed a resolution calling for the "immediate termination" of the war, a popular political stance that won the organization thousands of new members. In 1973, after an acrimonious internal debate, the ACLU became the first major national organization to call for Richard Nixon's impeachment. By the mid-1970's the politicization of the ACLU had, in many respects, become the salient feature of its organizational life.
Jewish involvement in the ACLU had been conspicuous and consistent since the organization's founding in 1920.40 Among those playing a direct role in establishing the ACLU were Felix Frankfurter, Stephen Wise, and Arthur Garfield Hayes. Louis Marshall, while not a card-carrying member, argued several cases on the ACLU's behalf during the 1920's, as did his law partner Samuel Untermeyer. Morris Ernst, who was instrumental in organizing both the American Newspaper Guild and National Lawyer's Guild during the 1930's, served as ACLU general counsel for many years. In 1937, when the ACLU first engaged in the legal defense of Nazis, it was Ernst and Hays who urged Mayor La Guardia of New York to approve the use of city property for a Nazi meeting. Hays also aided the attorney for the (Nazi) Friends of New Germany in court proceedings appealing a prohibition of meetings by that group in New Jersey.
In 1955 Osmond K. Fraenkel, who had assisted Ernst in preparing the defense for the Scottsboro case, became general counsel to the ACLU. In the 1960's and 1970's Aryeh Neier played a crucial role in the organization. Many staff attorneys and affiliate executives, including David Goldberger in Chicago and David Fishlow and Ruth Jacobs in San Francisco, are Jewish. When Neier resigned as executive director in October 1978, Ira Glasser, a New Yorker, running against Marvin Schacter of Los Angeles, was elected to succeed him.Despite the large number of Jews in leadership positions in the ACLU during the latter half of the 1960's and throughout the 1970's, the organization manifested a cold indifference to the concerns of the Jewish community.
Neier and his Jewish colleagues were representative of a "new politics" oriented group of civil rights attorneys and social policy experts for whom the ethnic concerns of Jews—whether the welfare of the State of Israel, or the institutional needs of the Jewish community, or just the protective comfort of political representation—were at best a peripheral matter. The focus of their attention was the political agenda and rhetoric of the New Left, Black Power and the Third World. Thus, it is not surprising that on issue after issue, between 1966 and 1978, the ACLU took a stand that was seen by many as being inimicable to Jewish interests. The ACLU, for example, supported the proposal by the Lindsay administration in New York City to establish a civilian review board for the police department. During the New York City teachers' strike, the organization backed demands by Black militants for community control of the schools. The ACLU came to the defense of the openly anti-Jewish Black Panthers in their confrontations with the police.
Finally, the ACLU opposed Marco De Funis and Alan Bakke in their suits charging reverse discrimination.
The New Black Panther Party is a virulently racist and anti-Semitic organization whose leaders have encouraged violence against whites, Jews and law enforcement officers. Founded in Dallas, the group today is especially active on the East Coast, from Boston to Jacksonville, Fla. The group portrays itself as a militant, modern-day expression of the black power movement (it frequently engages in armed protests of alleged police brutality and the like), but principals of the original Black Panther Party of the 1960s and 1970s— a militant, but non-racist, left-wing organization — have rejected the new Panthers as a "black racist hate group" and contested their hijacking of the Panther name and symbol.-- New Black Panther Party, by Southern Poverty Law Center
Against the background of the ACLU's drift to the left and its indifference to the Jewish communal agenda, the organization's defense of the Nazis appeared to many Jews as the final insult. Small wonder that the ACLU suffered significant membership losses.COMBATTING THE NAZIS: THE LEGISLATIVE FRONT
In Jewish communal circles throughout the United States much effort has been made over the past few years to develop a legal strategy to combat Nazism in America. The enactment of effective anti-Nazi legislation, however, has proved to be no simple matter. Indeed, the inability to pass such legislation has been a source of frustration and concern to Jewish communal leaders.
The experience in San Francisco offers insight into the difficulties that arise in attempting to combat Nazis by legal means.4' During the early months of 1974, as was noted above, Nazi party members began to sit in on public meetings of the city's Board of Education. Despite the heated objections of Jews and Blacks in the audience, to whom the Nazi uniform symbolized both racism and genocide, there was no legal way to halt Nazis. As an official statement of the San Francisco Human Rights Commission issued at the time put it: "The Board of Education must let anyone enter the hall when there is a public meeting in session . . . The Board of Education must let anyone speak . . . The City of San Francisco and San Franciscans detest the Nazis, but we must allow them to speak, within the limits of the First Amendment. The courts would force us to let them speak, if we did not, and the courts would be right."42 The problem posed by the presence of the Nazis at the Board of Education meetings was similarly articulated by the Jewish Community Relations Council: "The presence of that [Nazi] symbol at the Board of Education meeting is disgusting and disturbing to all of us. It is also frustrating in the extreme because there is no way to ban the presence of these individuals from a public meeting without destroying our most basic principle of liberty, and therefore handing a great victory to the Nazis . . ."43
After consulting with Jewish communal leaders, supervisors Quentin Kopp and Robert Mendelsohn proposed a new municipal ordinance which would have made it illegal to wear the uniform or insignia of the Nazi party in public. The proposed ordinance, however, while enjoying widespread popular support, both within the Jewish and the general community, never became law. On May 20 City Attorney O'Connor advised the Board of Supervisors that it could not legally outlaw the wearing of Nazi, or any other, uniforms in public. The United States Supreme Court, he indicated, had in the past consistently ruled that the wearing of political symbols is "symbolic speech" protected by the free speech provisions of the First Amendment. In 1969, for example, the Court ruled (Tinker v. Des Moines) that students could not be prevented from wearing black armbands to school in order to protest the Vietnam war.
In 1960 a Miami ordinance prohibiting the wearing of Nazi (or Communist) uniforms in public places was struck down by a state court.
In the wake of O'Connor's advisory opinion, the Board's State and National Affairs Committee called upon the state legislature to deal with the matter. During the next three years, however, the legislature in Sacramento failed to enact any anti-Nazi legislation. Hence, at the time of the opening of the Rudolf Hess bookstore in 1977 there was still no legal way to ban the public display of Nazi symbols. It was in response to this legislative void that Supervisor Dianne Feinstein, as was noted above, introduced a new resolution urging the legislature to bar the display of the swastika and the wearing of the Nazi uniform in public. In co-sponsoring this resolution, Supervisor Mendelsohn said that the display of Nazi symbols and uniforms "provokes acts of violence and threatens the public peace." Mendelsohn and the other supervisors, however, expressed doubt about the proposal's chances of being enacted as state law. This in fact proved to be the case.
One other unsuccessful effort at passing anti-Nazi legislation in San Francisco is worth noting. In early 1978 it was revealed that the Nazis were holding meetings at the Wawona Clubhouse, a rented public facility in the city-owned Sigmund Stern Grove. The JCRC issued a statement protesting "the private use of public facilities by Nazi groups, which exclude people on the basis of race and religion." On the basis of a municipal ordinance requiring that there be no discrimination in the rental of city property, Supervisor Kopp sought to evict the Nazis. The City Attorney, backed by the ACLU, ruled in March, however, that the ordinance in question did not apply to the Nazis, because of an amendment stating that rentals of less than 30 days a year would be exempt from the law's provisions. The Jewish community's efforts to combat Nazi activity were thus once again thwarted.
In Chicago the Jewish community has found itself similarly powerless to enact anti-Nazi legislation. Illinois State Senators John Nimrod and Howard Carroll introduced two bills in May 1978; one would have empowered local officials to deny parade permits for demonstrations which might result in defamation of a group because of race, creed, color, or religion; the other would have allowed for the rejection of parade permits if there were "reasonable apprehension" about violence occurring as a result of the display of "quasi-military" uniforms.44 The first bill, by making group defamation criminally punishable, might have served as a model for similar laws in other states. Illinois, it should be noted, had first enacted group libel legislation in 1917 (it was upheld by the United States Supreme Court in 1952 in a five-to-four decision), but the law had been repealed in 1964.
After the Illinois State Senate adopted the two bills, the state's Assembly Judiciary Committee met to consider the matter. Spokesmen for Skokie's Jewish community, including Rabbi Laurence Montrose and Erna Gans, president of the B'nai B'rith Korczak Lodge in Skokie, testified on the bill's behalf. They urged the legislators to speak out by passing the statutes, just as the residents of Skokie had spoken out by resisting the Nazi demonstration. Joel Sprayregen, a prominent Chicago civil liberties attorney, who had been a staff counsel for the ACLU in the early 1960's and had subsequently served for several years as a member of its board of directors, testified in favor of the proposed bills, while ACLU executive director Aryeh Neier testified in opposition. Following the Sprayregen-Neier debate, the committee voted. To the shock of the many Holocaust survivors in attendance, the anti-Nazi bills were soundly defeated; the Judiciary Committee voted fifteen to five against the group libel bill and sixteen to four against the bill introduced by Carroll. Chicago's Jewish community viewed the defeat of the bills as a moral victory for the Nazis, who called a press conference to celebrate the legislature's inaction.45
In Milwaukee efforts at enacting anti-Nazi legislation met with similar results. The Brennan ordinance, patterned on the Illinois bill prohibiting group defamation, won the support of the Milwaukee County Board of Supervisors but was subsequently defeated in the Common Council of the City of Milwaukee. In the view of political observers, the ordinance's defeat was largely due to the efforts of the Wisconsin chapter of the ACLU, which vigorously defended the Nazis' constitutional rights.46COMBATTING THE NAZIS: THE EDUCATIONAL FRONT
As legislative efforts to combat neo-Nazism proved increasingly ineffective, American Jewry turned its attention to the educational front. There was growing support within the Jewish community for the introduction of Holocaust study courses on both the high school and university levels. During the 1977-78 school year, such courses were in fact mandated in the New York City and Philadelphia school systems. Jews were concerned that the history of the Holocaust was little understood by young people, since most social studies texts and curricula avoided the subject. One survey of the 45 most widely-used high school, social studies textbooks revealed that 15 "omitted any mention of the Nazi persecution of Jews and 22 glossed over the facts."47
In April 1977 the San Francisco Conference on Religion, Race and Social Concerns, an interfaith social action group coordinated by JCRC associate director Rita Semel, announced the formation of a city-wide committee for "community education" against Nazism. A cross-section of Protestant, Catholic, and Jewish clergy and civic leaders, including Mayor George Moscone and Supervisors Kopp and Feinstein, agreed to join the committee, whose purpose would be "to focus on educating the public on what is behind the headlines . . . why Nazism is and should be anathema to a democratic society and why the fight against its ideology must be broadened and strengthened
." Plans called for the inservice training of teachers, as well as "education for the general public" through the showing of movies such as "Judgment at Nuremburg." "The teaching of social studies," noted Semel, "has changed so that World War II is barely mentioned in many courses now.
And we're now in the fourth generation. Not only haven't the kids lived through World War II, many of the teachers haven't either."48
Public education concerning Nazism took a significant step forward in April 1978 when NBC televised "Holocaust," a nine-hour, prime-time special dealing with Jewish fate under the Nazis. Jewish and Christian organizations, as well as NBC, developed a variety of discussion guides targeted for different audiences, to be utilized in conjunction with the show. Under the auspices of the National Jewish Welfare Board, 15 Jewish agencies joined together in preparing a "Holocaust Program Package" designed "to transform this TV special into a 'multi-media' educational tool for use in formal and informal Jewish educational settings."49 The National Council of Churches, in cooperation with the National Conference of Catholic Bishops and the American Jewish Committee, produced a four-page interreligious study and discussion guide for use by churches throughout the country. NBC developed its own discussion guide, which it distributed, through its 217 affiliated stations, free of charge to public schools across the nation.
The National Jewish Community Relations Advisory Council asked its constituent agencies to utilize "every possible channel to the non-Jewish community" to encourage public viewing of "Holocaust." In some cities cooperative efforts were undertaken by local NBC affiliates and Jewish community relations councils in arranging a pre-screening of the program for various religious, ethnic, and civic leaders. NJCRAC also encouraged its constituent agencies to organize follow-up programs to "Holocaust" and intergroup dialogues on various aspects of the Holocaust and contemporary neo-Nazism. "We are attempting," one NJCRAC leader noted, "to teach the lessons of the Holocaust to our non-Jewish neighbors. If we cannot stop Nazi appearances, if we must endure the anguish, must we not use every possible means to fasten the general public's attention onto the principles for which the Nazis stand?"50THE LESSONS OF SKOKIE
The threatened Nazi march through Skokie represented a radically new experience for many American Jews, especially those under the age of 35. As Eugene DuBow, organizer of the planned PAC counter-demonstration, noted, it had been many years since American Jewry was faced with the prospect of a major Nazi demonstration in an area heavily populated by Jews. The planned Nazi march in Skokie forced many Jews to weigh their commitment to civil liberties against their concern for Jewish security and abhorrence of Nazism.
There were Jews in Skokie who had the gnawing feeling that history was repeating itself, that Nazism was once again on the rise. "There are the echoes of history rumbling through your mind and ticking off similarities and parallels that are all too uncomfortable," said one Skokie resident. "Absurd analogies you say? Hitler started off small, bluffed and got what he wanted by promoting ideas contrary to what the vast majority of people and countries believed. He radicalized antisemitism. So has Collin. Hitler used the law to promote his 'rights' until he was in a position of power to have his will alone become law. So has Collin. His violence of words, deed and symbols are protected."51
There was a determination in the Skokie Jewish community, and among Jews throughout the United States, not to sit idly by in the face of Nazi threats.
This was a much different communal response from that of the 1960's, when the policy of the organized Jewish community had been one of "quarantine," i.e., to ignore most Nazi incidents in the hope that the Nazis, bereft of publicity and media attention, would disappear.52 By 1978 leaders of the National Jewish Community Relations Advisory Council were seriously reconsidering the wisdom of the quarantine approach. "I am troubled by our 1963 conclusion that public protests against Nazi appearances merely provide them with increased publicity and bolster their image of martyred heroes," stated NJCRAC chairman Theodore Mann. "It seems to me curiously outdated . . . The concept of quarantine as the general rule seems to be an anachronism." On the contrary, Mann argued, "Jewish leadership should be able to fashion a counter-demonstration or protest march or meeting, with signs and literature and releases to the media depicting the bestial acts of Nazi Germany, which would provide both an outlet for Jewish anguish and a lesson for our neighbors as to what the swastika really means." 53 A shift from quietism toward communal activism vis-a-vis the Nazis was apparent in San Francisco, where JCRC urged the "organized Jewish community to speak out vociferously and take prompt and militant action against the Nazis in any way that will hurt the Nazi cause."54 A reporter noted that in Skokie "Jews, who normally would be appalled at the thought of taking to the streets, now are thinking the unthinkable." 55
Sol Goldstein, chairman of the PAC Committee on American and Jewish Security, maintained that it was the determination of thousands of people to confront the Nazis that had scared them off. Goldstein emphasized that he regarded Skokie as only "one battlefront" of a much larger "war." "This battlefront gained a victory. But the war is not over . . . We will come to any place the Nazis will appear." The lesson of Skokie, Goldstein maintained, was that the Nazis would back down "when confronted by a determined American public."56 In commenting on the cancellation of the Nazi march, National Jewish Community Relations Advisory Council chairman Theodore Mann noted: "The important lesson of Skokie is that the Jewish survivors of the Nazi death camps found that they were not alone as they were 40 years ago." 57
Skokie's Holocaust survivors had the satisfaction of having kept the Nazis out of their community. Their active opposition helped educate a generation that had grown up with only a dim awareness of what Nazism was all about. "Sure, the Nazis have gotten publicity because of our opposition," said Korczak B'nai B'rith lodge president Erna Gans, "but we've also raised the consciousness of the American people. Schools are beginning to teach courses on the Holocaust. People from around the country are standing with us. When I talk to groups, they all want to know what they can do to keep Nazism from happening here."58
1. Total Nazi membership in the United States in 1977 was between 1,500 and 2,000. There were probably no more than 20 activists each in Chicago and San Francisco. See Milton Ellerin, "Intergroup Relations," AJYB, Vol. 79, 1979, p. 117.
2. Samuel Stouffer, Communism, Conformity and Civil Liberties (Garden City, 1955), p. 143. See also Lawrence H. Fuchs, The Political Behavior of American Jews (Glencoe, 1956), pp. 187-190.
3. Everett Carll Ladd, Jr., "Jewish Life in the United States: Social and Political Values," paper delivered at YIVO Institute for Jewish Research Colloquium, New York City, May 28-29, 1978, pp. 31-32.
4. Alan Fisher, "Continuity and Erosion of Jewish Liberalism," American Jewish Historical Quarterly, December 1976, pp. 330-334.
5. Various explanations have been put forward to account for Jewish support for civil liberties. Some have pointed to Jewish religious values derived from biblical and talmudic antecedents as the source. Charles S. Liebman has suggested that Jewish liberalism in general, and the Jewish commitment to civil liberties in particular, is rooted "in the search for a universalistic ethic to which a Jew can adhere but which is seemingly irrelevant to specific Jewish concerns . . ." See Charles Liebman, The Ambivalent American Jew (Philadelphia, 1973), pp. 135-159.
6. Abner Mikva, "Skokie is Different," Moment, June 1978, p. 43.
7.The narrative of events in Skokie is developed from a number of sources: Marc Stern, "The Dilemma of Skokie: Protecting Civil Liberties or Curbing the Nazis?" Research Report. Institute of Jewish Affairs, London, August 1978, pp. 3-6; David Hamlin, "Swastikas and Survivors: Inside the Skokie-Nazi Free Speech Case," Civil Liberties Review, March-April 1978, pp. 8-33; and selected Jewish Telegraphic Agency Daily News Bulletins, 1977 and 1978.
8. Stern, loc. cit., p. 3.
9. The U.S. Supreme Court subsequently refused to review the Illinois Supreme Court's dismissal, thus upholding the lower court's decision in the Goldstein suit.
10. Kathryn Mclntyre, "One Man's War with Nazis," US Magazine, April 18, 1978, p. 56.
11. Chicago Sun Times, June 20, 1978, p. 12.
12. Kopp is a former member of the ACLU. He resigned in protest over the organization's growing politicization. Interview with Quentin Kopp, April 24, 1978.
13. New York Times, August 4, 1974, p. 37.
14. San Francisco Examiner, July 16, 1974, p. 1.
15. San Francisco Chronicle. July 18, 1974, p. 3.
16. San Francisco Examiner. April 5, 1977, p. 26.
17. San Francisco Jewish Bulletin. May 13, 1977, p. 5.
18. San Francisco Examiner. April 5, 1977, p. 5.
20. The charges against the Weisses were subsequently dropped.
21. Earl Raab, "The Insensitives—'Neutral' on Anti-Semitism," Midstream, August-September, 1978, p. 59.
22. Mathew Weinberg, "Rebuttal," editorial on "Freedom of Speech," May 4-5, 1977, transcribed and reprinted by KGO-T.V., San Francisco.
23. Quoted in Mikva, loc. cit., p. 46.
24. Interview with Aryeh Neier, April 5, 1978.
25. Chaplinsky v. New Hampshire, 1942. For an interesting discussion of the Chaplinsky ruling see Hadley Arkes, "Civility and the Restriction of Speech: Rediscovering the Defamation of Groups," in Philip B. Kurland (ed.), Free Speech and Association: The Supreme Court and the First Amendment (Chicago, 1975), pp. 414-22.
26. David Fellman, "Constitutional Rights of Association," in Philip B. Kurland, Ibid, p. 44.
27. See Aryeh Neier, Defending My Enemy (New York, 1979), passim.
28. This point is made by Marie Syrkin in "Sadat, Skokie and Cosmos 954," Midstream, March 1978, pp. 65-66.
29. Hadley Arkes, "Marching Through Skokie," National Review, May 12, 1978, p. 593.
30. George F. Will, "Nazis: Outside the Constitution," Washington Post, February 2, 1978, p. A19.
31. New York Times, March 20, 1978, p. 20.
32. Quoted in Fred Ferretti, "The Buck Stops With Gotbaum," New York Times Magazine. June 4, 1978, p. 89.
33. Phineas Stone, New York Jewish Week. August 7, 1977, p. 14.
34. Maynard Wishner, "American Nazis and the First Amendment," Sh'ma. May 27, 1977, p. 136.
35. Stern, be. cit., p. 6, and American Jewish Congress press release, Feb. 2, 1978, p. 1.
36. Jim Mann, "Hard Times for the ACLU," The New Republic, April 15, 1978, pp. 12-15. The decline in ACLU membership since 1976 is not attributable solely to the Skokie controversy. A good many ACLU members were outraged by the organization's decision to defend Ku Klux Klan members stationed at the Marine Corps base at Camp Pendleton, California, after they were attacked by a group of Black marines in November 1976. See J. Anthony Lukas, "The ACLU Against Itself," New York Times Magazine. July 9, 1978, p. 11.
37. Not all groups in the Jewish community thought it wise for Jews to disassociate themselves. The Union of American Hebrew Congregation's Commission on Social Action of Reform Judaism stated that "one can disagree strongly with the approach of the ACLU, but it would be destructive of our deepest Jewish interests to contribute to the weakening and undermining of the ACLU on the American scene." This position was also supported by the Central Conference of American Rabbis, the Reform rabbinic group. See Albert Vorspan, memo on "Skokie," Commission on Social Action of Reform Judaism, Union of American Hebrew Congregations, June 15, 1978. The UAHC position is further developed in its "Working Paper on Skokie," on file at the Commission on Social Action of Reform Judaism, Union of American Hebrew Congregations, New York City.
38. Mann, loc. cit., p. 13. See also Joseph W. Bishop, Jr., "Politics and the ACLU," Commentary, December 1971, pp. 50-58.
39. J. Anthony Lukas, loc. cit., p. 20.
40. In recounting the history of the ACLU, Roger Baldwin, the guiding spirit behind the organization, stated that he could not "remember a time from when [he] first began when there was not a very strong Jewish presence" in the ACLU. See Interview with Roger Baldwin, November 16, 1973, p. 16, on file at William E. Wiener Oral History Collection, American Jewish Committee.
41. The discussion which follows is based on David G. Dalin. Public Affairs and the Jewish Community: The Changing Political World of San Francisco Jews, unpublished Ph.D. dissertation, Brandeis University, 1977, pp. 152-155.
42. San Francisco Jewish Bulletin, January 25, 1974, p. 1.
44. JTA Daily News Bulletin, May 30, 1978, p. 4.
45. Neier, op. cit., pp. 62-65.
46. Zvi Deutsch, "Milwaukee Jews Counter Nazi Threat," Jewish Currents, September 1977 p. 6.
47. Judith Herschlag Muffs, "US Teaching on the Holocaust," Patterns of Prejudice, May- June 1977, p. 29.
48. San Francisco Examiner, April 7, 1977, p. 4.
49. "Materials for NBC-TV Holocaust Series," National Jewish Community Relations Advisory Council memo, February 24, 1978, p. 2.
50. Theodore R. Mann, address delivered at NJCRAC plenary session, Tucson, Arizona, January 22-23, 1978, p. 5.
51. Arthur J. Sabin, "Skokie," Sh'ma. September 15, 1978, p. 163.
52. The "quarantine" strategy was first developed in the 1940's. See S. Andhill Fineberg, "Checkmate for Rabble-Rousers," Commentary, September 1946, pp. 220-26 and S. Andhill Fineberg, Deflating the Professional Bigot (New York, 1960), pp. 8-10.
53. Theodore R. Mann, address delivered at NJCRAC plenary session, Tucson, Arizona, loc. cit., p. 5. NJCRAC memo to member agencies, February 24, 1978.
54. "How to Prevent Nazism, discussion guide, Jewish Community Relations Council, San Francisco, 1978, p. 49.
55. San Francisco Examiner, June 26, 1977.
56. JTA Daily News Bulletin, June 27, 1978, p. 4.
57. Theodore R. Mann, NJCRAC plenary address, op. cit.
58. Quoted in John J. Camper, loc. cit., p. 34.