The conflict about the meaning of free speech went on through the 1920s, Holmes and Brandeis persisting in their view and expressing it in strongly worded dissents. In one sense it was a curious performance by the two of them, for each had a deep commitment to the Supreme Court as an institution and thought that division among the justices should be avoided when possible.

Lewis, Anthony (1992). Make No Law: The Sullivan Case and the First Amendment. Vintage. pp. 82-83. ISBN 0679739394.