“Slavery cannot tolerate free speech,” Frederick Douglass had said, in his “Plea for Free Speech.”54 The seventeenth-century battle for freedom of expression had been fought by writers like John Milton, opposing the suppression of religious dissent; the eighteenth-century struggle for the freedom of the press had been fought by printers like Benjamin Franklin and John Peter Zenger, opposing the suppression of criticism of the government; and the nineteenth century’s fight for free speech had been waged by abolitionists opposing southern slave owners, who had been unwilling to subject slavery
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