Teaching Our Journal
Breaking the White Circle: How the Press and Courts Quieted a Chicago Hate Group, 1949–1952
Vol. 38, No. 4, 2021
by Erika J. Pribanic-Smith, University of Texas at Arlington, and Jared Schroeder, Southern Methodist University
Joseph Beauharnais founded the White Circle League in 1949 in response to the influx of Black families moving into formerly all-white Chicago neighborhoods. Beauharnais circulated recruitment literature and a short-lived newspaper called White Circle News, filled with rhetoric emphasizing the perceived lawlessness of Blacks and the dangers forced integration posed to whites. Civil rights organizations and individuals flooded the Illinois governor and secretary of state with letters complaining that the League’s charter as a registered non-profit should be revoked. The state did revoke the charter, and Beauharnais faced charges that he violated a section of the Illinois Criminal Code declaring attacks on any group of people based on their race, religion, or color unlawful. Both the Illinois Supreme Court and the US Supreme Court upheld Beauharnais’s conviction; the latter decision has been cited more than 300 times.
This story illustrates the dilemma created in cases of hate speech. Many in Illinois—and some Supreme Court justices—considered the racist nature of Beauharnais’s expression intolerable. However, the US Supreme Court was divided. Four dissents asserted that free expression should be granted to nearly all speech, including that which some might consider objectionable. The Chicago Tribune, one of few allies Beauharnais had among the city’s press, concurred.
Other newspapers in Chicago—most notably the city’s alternative press—criticized the white supremacist nature of Beauharnais’s rhetoric, comparing him to the Ku Klux Klan and to Nazi leader Adolph Hitler. Beauharnais specifically blamed the Black Chicago Defender and the Communist Worker for the White Circle League’s failure. The latter not only blasted Beauharnais in numerous articles, but it also convinced the White Circle News’s publisher to stop printing the newspaper and a Boys Club venue to ban the organization from having future gatherings there. Furthermore, the FBI, which amassed a substantial file on Beauharnais and his League, collected Worker articles as a key source.
After reviewing the societal and legal environments in which this story occurred, our article examines Beauharnais’s White Circle League literature, the means Chicago’s press and other organizations used to counter it, the legal ramifications of Beauharnais’s rhetoric, and the aftermath of the Supreme Court’s ruling. We supplemented resources from the FBI file with additional government documents, newspaper articles, and court cases. This article would be a valuable addition to courses in media law, media history, or race and media.
Resources
The White Circle League’s FBI file is available in its entirety at archive.org (https://archive.org/details/WhiteCircleLeagueOfAmerica/). The file includes all Worker clippings cited in our article.
Supreme Court Cases, including Beauharnais v. Illinois, can be found at https://supreme.justia.com/
Issues of the Chicago Defender are available via ProQuest Historical Newspapers database
Issues of the Chicago Tribune can be found at Newspapers.com
Discussion Questions
- In light of increasing extremist expression in virtual communities, how effective do you think the Beauharnais approach to limiting speech that damages the reputation of an entire group of people would be now?
- The Supreme Court has turned its back on Beauharnais as a precedent, favoring New York Times v. Sullivan and similar cases that followed. Why do you think that is?
- Why would a Communist newspaper be concerned about the White Circle League’s activities?
- Why do you think Chicago’s Black press was so reserved in its reporting about Beauharnais’s behavior and his Court case?
- What do you think about the Chicago Commission on Human Relations’ efforts to regulate racial reporting in the city’s newspapers? Why do you think the Chicago Tribune chose to ignore many of those regulations?
Exercise 1
The Beauharnais decision occupies an unusual position in the Supreme Court’s history. It is in some ways a junction between defamation cases and hate speech, but it isn’t a dominant precedent.
This exercise challenges students to grasp Beauharnais’s unique place in free-expression history. Students are provided a list of three cases that came after Beauharnais: New York Times v. Sullivan, Virginia v. Black, and Snyder v. Phelps. Each case has an important tie-in with the issues that were central in Beauharnais.
Students are asked to compare and contrast the Court’s reasoning in Beauharnais with the Court’s reasoning in each of the three subsequent cases. This would be a written exercise followed by an in-class discussion about the connections students made between Beauharnais and the other cases.
Exercise 2
The alternative press played an important role in advocating against Beauharnais’s White Circle League. In this exercise, students are given a set of articles from three sources—the Worker, the Chicago Defender, and the Chicago Tribune—and tasked with analyzing the coverage.
They are asked to respond to four primary questions:
- How did the different news outlets frame the actions and rhetoric of Beauharnais and the White Circle League?
- How did the news organizations frame their coverage of Beauharnais’s trials?
- Why was their coverage so different? What historical and cultural factors from the period likely influenced the diverging frames?
The exercise includes a written response to these prompts that sets up an in-class discussion about the questions.
Exercise 3
This exercise encourages students to explore how their local newspapers have covered the actions of white nationalist or white supremacist groups.
One option would be to have students or groups of students each select a different newspaper local to their university’s region and trace coverage of white supremacist activities over time, from the birth of the Ku Klux Klan in the Civil War era to present, and explore how the coverage changed, including the following:
- How much space did the newspaper devote to white supremacist activities, in news coverage and in editorials?
- What was the tone of the coverage?
- What language did writers use when describing the organizations and their activities?
This would be a several-week project culminating in presentations to the class, followed by discussion of common themes that emerged in the presentations as well as any differences among the newspapers studied.
For a shorter assignment, the course instructor could select recent stories from newspapers local to the university’s region about the activities of white nationalist or white supremacist groups and ask students to compare the tone and language used in those stories to the way Chicago’s newspapers discussed the White Circle League.
Further reading
Jon Bekken, “The Chicago Newspaper Scene: An Ecological Perspective,” Journalism & Mass Communication Quarterly 74, 3 (1997): 490-499.
Aimee Edmondson, In Sullivan’s Shadow: The Use and Abuse of Libel Law during the Long Civil Rights Struggle (Amherst: University of Massachusetts Press, 2019).
Mark S. Hamm, “From the Klan to Skinheads: A Critical History of American Hate Groups,” in Barbara Perry and Brian Levin, eds., Hate Crimes, vol. 1: Understanding and Defining Hate Crime (Westport, CT: Praeger, 2009).
Arnold R. Hirsch, Making the Second Ghetto: Race and Housing in Chicago, 1940-1960 (University of Chicago Press, 1998).
Ethan Michaeli, The Defender: How the Legendary Black Newspaper Changed America, from the Age of the Pullman Porters to the Age of Obama (Boston: Houghton Mifflin Harcourt, 2016).
Clarence Taylor, “Race, Class, and Police Brutality in New York City: The Role of the Communist Party in the Early Cold War Years,” Journal of African American History 98, 2 (2013): 205-228.