After handing out literature advocating the establishment of socialism in the United States, Benjamin Gitlow was convicted of violating a New York law criminalizing the advocacy of overthrowing the government. The Supreme Court upheld Gitlow’s conviction, ruling that New York’s restriction on freedom of speech was a reasonable one because it prohibited speech that had a tendency to endanger public safety. Of broader significance was the fact that the Court, for the first time, held that the First Amendment applied to the states by virtue of the Due Process clause of the Fourteenth Amendment.