Charlotte Anita Whitney was a founding member of the Communist Labor Party of California. She was prosecuted under the California Criminal Syndicalism Act of 1919 for her part in organizing a group that called for economic and political change through the use of violence. She argued in court that it was not her intent for the organization to use violence to achieve its ends and that the California law violated her free speech rights under the First Amendment. Whitney was convicted, and her conviction was affirmed by the U.S. Supreme Court.