The Vinson Court upheld a group libel law in its 5–4 decision in Beauharnais v. Illinois (1952). State officials charged white supremacist Joseph Beauharnais with violating a law that prohibited any publication that “portrays depravity, criminality, unchastity, or lack of virtue of a class of citizens, of any race, color, creed or religion” or that “exposes the citizens of any race, color, creed or religion to contempt, derision, or obloquy.”

Beauharnais, president of the White Circle League, distributed literature that advocated for separation of the races, warned against “mongrelization” by the “Negro” race, and included other hateful comments. He appealed his conviction in the lower courts all the way to the U.S. Supreme Court. Justice Felix Frankfurter wrote that the state of Illinois had a strong interest in passing laws to prohibit racial unrest. He noted that “Illinois has been the scene of exacerbated tension between races, often flaring into violence and destruction.” He reasoned that the state could reasonably pass a law that would “curb false or malicious defamation of racial and religious groups, made in public places and by means calculated to have a powerful emotional impact on those to whom it was presented.”