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The Growing Assault on Truth and Memory




The Battle for the Campus

This is not a public stagecoach that has
to take everyone who buys a ticket.
Benjamin Franklin (1)

In the early 1990s American college campuses became loci of intensive activity by a small group of Holocaust deniers. Relying on creative tactics and assisted by a fuzzy kind of reasoning often evident in academic circles, the deniers achieved millions of dollars of free publicity and significantly furthered their cause. Their strategy was profoundly simple. Bradley Smith, a Californian who has been involved in a variety of Holocaust denial activities since the early 1980s, attempted to place a full - page ad claiming that the Holocaust was a hoax in college newspapers throughout the United States. The ad was published by papers at some of the more prestigious institutions of higher learning in the United States.

Entitled "The Holocaust Story: How Much Is False? The Case for Open Debate," the ad provoked a fierce debate on many of the campuses approached by Smith. His strategy was quite straightforward: He generally called a paper's advertising department to ascertain the charge for publication of a full - page ad and then submitted camera - ready copy and a certified cheek in the proper amount. On occasion he inquired in advance whether a paper would be willing to run this par

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ticular ad. * Even when he was rejected, the attempt to place the ad won him significant media attention. ( 2 ) Campus newspapers began to use his name in headlines without identifying him, assuming readers would know who he was. Articles, letters, and op - ed pieces defended Holocaust denial's right to make its "views" known. But not all the results were necessarily what Smith would have wanted. On some campuses there was a backlash against him and Holocaust denial. Courses on the Holocaust that had languished on the back burner for an extended period materialized in the next semester's offerings. Campus administrators admitted that the ad constituted the final push necessary to move these courses from the planning stage to the schedule books. ( 3 ) Professors from a wide variety of disciplines included discussion of the Holocaust in their courses. Movies, speakers, photographic exhibits, and other presentations relating to the Holocaust were brought to campus. Students participated in rallies, teach - ins, and protests.

This response prompted some observers to argue that the controversy had a positive impact. Students had become increasingly aware not only of the Holocaust but of the contemporary attempt to subvert history and spread antisemitism. While this may be a relatively accurate analysis of the immediate outcome of Smith's endeavor, there is another more sobering and pessimistic aspect to the matter. Analysis of the students', faculty's, and administration's responses reveals both a susceptibility to the worst form of historical revisionism and a failure to fully understand the implications of Holocaust denial, even among those who vigorously condemned it.

This was not Smith's first use of college newspapers to spread Holocaust denial. For a number of years Smith, along with other deniers, had been placing small ads containing the phone number and address of the Committee on Open Debate on the Holocaust (CODOH), an organization Smith had created with fellow denier Mark Weber in 1987. According to the ADL, CODOH was initially funded by the late


William Curry, a Nebraska businessman known for his antisemitic ac6 tivities. In 1986, he first attempted to place an ad denying the Holocaust in a campus newspaper. He sent one thousand dollars to the Daily Nebraskan for a full - page ad claiming the Holocaust was a hoax. ( 4 ) The paper rejected the ad. Shortly thereafter Curry died, and Smith continued his work.

Smith claims that he has no connection to any other denial group and his only association is with CODOH. He has had a long - standing association with the IHR, serving as a contributing editor of its newsletter since June 1985. At the time he was placing the ads he still maintained a relationship with it. ( 5 ) In 1986 he launched the IHR radio project, writing a regular column on the project for the IHR's newsletter, in which he touted his success in getting Holocaust denial onto the radio. Under the auspices of the IHR he planned to tour colleges and universities to speak about "Holocaust fraud and falsehood." ( 6 ) Smith's objective was not to "plant seeds " for coming gene rations bu t to "take revisionist scholarship directly into our universities NOW!" In a letter to his followers he announced that the IHR had guaranteed to pay a portion of both his "start - up costs" and his "on -going expenses." (7)

Before becoming involved with the IHR's radio project, Smith published Prima Facie, which he dedicated to "monitoring Holocaust Cultism, Censorship and Suppression of Free Inquiry." In it he attacked Mel Mermelstein, who had successfully challenged the IHR's demand for "proof" that the Holocaust happened. Smith's description of Mermelstein -- as a "yokel" who had sued the institute because it refused to believe that "a hank of hair and a jar full of ashes proves" that Jews were "exterminated" in gas chambers -- typified the tone of the newsletter. Mermelstein had developed a "tongue so twisted he could drill his own teeth." ( 8 )

Articles from Prima Facie have been reprinted in Spearhead, the publication of the right - wing extremist British National party. One such article referred to a wire service report of how a Gestapo officer watched with a smile as his German shepherd dog killed an elderly Jew in Poland in 1942. Smith's use of sarcasm in his attempt to cast doubt on the story was a hallmark of his style.


Smith's accomplice was Mark Weber, co - director of CODOH, (10) one of the more active spokesmen for Holocaust denial, and a former member of the National Alliance, a neo - Nazi organization. Spotlight described Weber as the "shining star" of defense witnesses at the Zundel trial. (11) At the trial and in denial publications Weber has argued that the Jews who died were the "unfortunate victims" no t of an extermination program but of "diseas e and malnutrition brought on by the complete collapse of Germany in the final months of the war." Repeating a denial argument that had first been voiced by Austin App, Weber contended that if the extermination program had actually existed, the Jews found alive by the Allied forces at the war's end "woul d have long since been killed." (1 2 )

Born in 1951, he was educated in a Jesuit high school in Portland, Oregon. In an interview in November 1989 with the University of Nebraska Sower he expressed his concern about the future of the white "race" in the United States and about the future of the country. Weber contended that the country was heading in one of two possible directions. Either it would become "a sort of Mexicanized, Puerto Ricanized country," a result of the failure of "white Americans" to reproduce themselvesl or it would break up because of long - standing racial problems. He rejected the possibility of a unified American heritage or culture based on a multiplicity of races and groups. He did not think it desirable or feasible for "black Americans to be assimilated into white society." He seemed to yearn for a time when the United States was defined as a "white country" and nonwhites were "second - class citizens." This gave the country a "mooring, an anchor." He bemoaned the fact that "today we don't even have that.'' (1 3 ) As the newspaper controversy became more public and Weber became more publicly involved in denial activities, his ideas on race were increasingly left unarticulated.

One of the first papers approached by CODOH, which for all intents and purposes consisted of Smith and Weber, was Pennsylvania State University's Daily Collegian. After running the small ad that contained CODOH's number for a few weeks it dropped it in response to campus criticism. Smith immediately sent a series of letters to local newspapers accusing the Daily Collegian of trying to "suppress and even censor radical scholarship.'' (1 4 ) It may have been the "Sturm und Drang" he created with this small ad that persuaded him to expand his efforts.

Shortly after his failed attempt at Penn State he experienced the same problem with the Stanford Daily, which had been running a simi -


lar ad for a period of seven weeks. The editor cancelled it due to student protests. Smith, implying that Hillel, the Jewish student organization, controlled the Daily's coverage of other issues, including American politics in the Middle East, urged the editor to take a stand for "free inquiry and open debate" by running the ad. (1 5 ) He told Hillel students that it was in Jews' best interests to know the truth about the Holocaust. (1 6 )

In his publication Revisionist Letters, Smith tried to differentiate between antisemites who used Holocaust denial to attack Jews and his putative objective of uncovering the truth. He asserted that his editorial poli c y objective was to encourage "exposés of bigotry and antisemitism" in Holocaust "revisionism. " An article in the magazine argued that the participation of "Nazi apologists" in Holocaust denial circles precluded the participation of other supporters, particularly the radical left. (1 7 ) The author, Laird Wilcox, wondered how "revisionists" could argue that their speech was suppressed when there was a "substantial element in [their] own ranks that doesn't believe in it [free speech], except for themselves." (18) Smith reiterated this idea in a column in his local newspaper, admitting that although the "search for truth" about the Holocaust was not antisemitic, there were "bigots" in the movement who were "self - avowedly anti - Jewish and who used revisionist scholarship as an attack on Jews.'' (1 9 ) Smith seemed to be aware that any linkage of his efforts with extremist and racist groups would be a liability, particularly on campus.

His effort to distance himself from these overtly antisemitic groups was reflective of a shift by deniers to sever their overt ties to an array of neo - Nazi and extremist groups. Leonard Zeskind, the research director of the Center for Democratic Renewal in Kansas City, Missouri, and a respected specialist on extremism in America, categorized Smith ' s efforts as reflective of a general shift among "white supremacists" and extremists away from the political margins into the mainstream by avoiding any overt association with swastika - bedeeked or white - sheeted fascist groups. David Duke's re - creation of his past during the presidential camp aign was an examp le of this strategy, ( 20 ) which confuses many people who can easily identify the objectives of the Klan, White Aryan Nation, and Posse Comitatus but who find it more difficult to recognize extremism when it is cloaked in a seemingly rational and familiar garb.

The ad Smith began to circulate in the spring of 1991 contained the deniers' familiar litany of claims. It declared the gas chambers a fraud,

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photographs doctored, eyewitness reports "ludicrously unreliable," the Nuremberg trials a sham, and camp internees well fed until Allied bombings destroyed the German infrastructure in the most "barbarous form of warfare in Europe since the Mongol invasions," preventing food from being delivered and causing the inmates to starve. According to Smith the notion of a Nazi attempt to destroy the Jews was the product of Allied efforts to produce "anti - German hate propaganda." Today that same propaganda was used by powerful forces to "scape - goat old enemies," "seek vengeance rather than reconciliation," and pursue a "not - so - secret political agenda.'' ( 2 1)

He repeated the familiar protest that his sole objective was to uncover the truth through an open debate on the Holocaust -- debate that had been suppressed by a powerful but secret group on campus as part of their larger political agenda. "Let's ask these people -- what makes such behavior a social good? Who benefits?"

The ad contended that denial was forcing "mainline Holocaust historians" to admit the "more blatant examples" of Holocaust falsehoods. It was the deniers who had forced them to revise the "orthodox" Holocaust story. They had had to admit that the number of Jews killed at Auschwitz was far smaller than originally claimed, and had been made to confess that the Nazis did not use Jewish cadavers for the production of soap. It is correct that in recent years newly revealed doeumentation has allowed scholars to assess more precisely the number of Jews thought to have been murdered at Auschwitz. ( 22 ) ** It is also accurate that scholars have long written that despite wartime rumors to the contrary, the Nazis apparently did not use Jewish cadavers for soap. There has been a wide array of other "revelations" by Holocaust historians, all part of the attempt to uncover the full details of one of the most horrifying acts of human destruction. Smith suggested to his readers that scholars and others who work in this field, all of whom vigorously repudiate Holocaust denial, have been compelled to admit the truth of deniers' claims: "We are told that it is 'anti - Jewish' to question orthodox assertions about German criminality. Yet we find that it is Jews themselves like Mayer, Bauer, Hier, Hilberg, Lipstadt and others who beginning [sic] to challenge the establishment Holocaust story." 23 ) This notion -- that deniers have exposed the truth and mainline historians are scrambling to admit it -- remains a linchpin of the deniers' strategy.


It has two objectives: to make it appear that Jewish scholars are responding to the pressure of the deniers' findings and to create the impression that Holocaust deniers' "questions" are themselves part of a continuum of respectable scholarship. If establishment scholars, particularly those who are Jews, can question previously accepted truths, why is it wrong when Bradley Smith does the same?


Though much of the ad consisted of familiar rhetoric, Smith added a new twist that had a particular resonance on American college campuses. Since the 1980s the concept of "political correctness" has been a source of academic conflict. Conservative political groups have accused the "liberal establishment" of labeling certain topics politically incorrect and therefore ineligible for inclusion in the curriculum. Smith framed his well - worn denial arguments within this rhetoric, arguing that Holocaust revisionism could not be addressed on campus because "America's thought police" had declared it out of bounds. "The politically correct line on the Holocaust story is, simply, it happened. You don't debate it.'" Unlike all other topics students were free to explore, the Holocaust story was off limits. The consequences, he charged, were antithetical to everything for which the university stood. "Ideology replaces free inquiry, intimidation represses open debate, and .. . the ideals of the university itself are exchanged for intellectual taboos." ( 24 ) While most students who had to decide whether the ad should be published did not overtly succumb to CODOH's use of the political correctness argument, many proved prone to it, sometimes less than consciously -- a susceptibility evident in their justifications for running the ad. Among the first universities to accept the ad were Northwestern, the University of Michigan, Duke, Cornell, Ohio State, and Washington University. ( 25 ) ***

At the University of Michigan the saga of the ad had a strange twist. Smith mailed camera - ready copy directly to the Michigan Daily. According to the paper's business manager, the ad "slipped through without being read." When it appeared the business staff was appalled to learn what they had allowed to happen. On the following day they

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placed a six - column ad in the paper apologizing for running Smith's ad and acknowledging that its publication had been a mistake. They declared it a "sorrowful learning experience for the staff." ( 26 ) The manager told the Detroit Free Press, " We make mistakes like any organization ." ( 27 )

The story might well have ended here -- an example of faulty monitoring by a segment of the staff of the Michigan Daily -- but the issue became more complicated when, despite the fact that those responsible for running the ad acknowledged doing so as a mistake, the editorial board attempted to transform a blunder into a matter of principle. They recast a snafu as an expression of freedom of speech. On the same day that the advertising staff published its apology, the front page carried an editorial explaining that, though the editors found the ad "offensive and inaccurate," they could not condone the censorship of "unpopular views from our pages merely because they are offensive or because we disagree with them." ( 28 ) Editor in chief Andrew Gottesman acknowledged that had the decision been in his hands, he would have printed the ad. He argued that rejecting it constituted censorship, which the editorial board found unacceptable. ( 29 )

The following day a campus rally attacked both Holocaust denial and the paper's editorial policies. Stung by student and faculty condemnations and afraid that its editorial was being interpreted as an endorsement of CODOH, the editorial board devoted the next issue's lead editorial to the topic. Condemning Holocaust denial as "absurd" and "founded on historical fiction and anti - Jewish bigotry," they dismissed it as irrational, illogical, and ahistorical propaganda. The editors accurately as ses sed the ad as lacking intellectual merit . Nonethele ss , they continued to support its publication. Their powerful condemnation of Holocaust denial in general and Smith's ad in particular appeared under a banner quoting Supreme Court Justice Hugo Black's opinion on free speech: "My view is, without deviation, without exception, without any ifs, buts, or whereases, that freedom of speech means that you shall not do something to people either for the views they have or the views they express or the words they speak or write." ( 30 )

The strange set of circumstances at Michigan -- snatching a constitutional principle from the jaws of a mistake -- was further complicated by the entry of the university's president, James Duderstadt, into the debate. In a letter to the Daily he declared the ad the work of "a warped crank" and proclaimed that denying the Holocaust was to "deny our human potential for evil and to invite its resurgence." But he, too, defended the paper's decision, which was more of a nondecision, to run


the ad. The president asserted that the Daily had a long history of editorial freedom that had to be protected even when "we disagree either with particular opinions, decisions, or actions." Most disturbing was Duderstadt's elevation of Smith's prejudices to the level of opinions.

There was no doubt about the message the editors and the president were trying to convey: As absurd, illogical, and bigoted as the ad may be, First Amendment guarantees were paramount. The dictates of the American Constitution compelled the Daily to publish. None of those involved seemed to have considered precisely what the First Amendment said: "Congress shall make no law ... abridging the freedom of speech or of the press." Those who argued that free speech guarantees acceptance of the ad ignored the fact that the First Amendment prevents gosernment from interfering in any fashion with an individual's or group's right to publish the most outlandish argument. (31) The New York Times made this point in an editorial when it adamantly repudiated the notion that this was a First Amendment question: "Government may not censor Mr. Smith and his fellow 'Holocaust revisionists,' no matter how intellectually barren their claims." ( 32 )

To call rejection of the ad censorship was to ignore the fact that, unlike the government, whose actions are limited by the First Amendment, these papers do not have a monopoly of force. ( 33 ) If the government denies someone the right to publish, they have no other option to publish in this country. But if a paper rejects someone's column, ad, or letter, there are always other publications. The First Amendment does not guarantee access to a private publication. It is designed to serve as a shield to protect individuals and institutions from government interference in their affairs. It is not a sword by which every person who makes an outlandish statement or notorious claim can invoke a Constitutional right to be published. # Nor did the Michigan Daily seem to notice how Justice Black, whom they quoted, framed it: "you shall not do something to people...." No one was advocating "doing" anything to Smith.

One of the most ardent advocates of the free - speech argument was the Duke Chronicle. In an editorial column the editor in chief, Ann Heimberger, justified the paper's decision by acknowledging that while

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the paper knew it could reject the ad, it "chose" to accept it as an expression of the paper's desire to "support the advertiser's rights." The editorial board believed that it was not the paper's responsibility to protect "readers from disturbing ideas," but to "disseminate them." ( 34 )

Echoing his Michigan colleague, Duke University president Keith Brodie repeated the free - speech defense in a statement that, though it contained a strong refutation of the ad, was more vigorous in its support of the Chronicle's publication of the ad. To have "suppressed" the ad, he argued, would have violated the university's commitment to free speech and contradicted its "long tradition of supporting First Amendment rights." ( 35 )

When the Cornell Daily Sun ran the ad, the editors justified the decision in an editorial statement warning that "page twenty will shock most readers" but proclaimed that it was not the paper's role to "unjustly censor advertisers' viewpoints." Echoing their colleagues on many of the other campuses that printed the ad, the editors declared that they decided to print it because the "First Amendment right to free expression must be extended to those with unpopular or offensive ideas." ( 3 6) Neeraj Khemlani, the editor in chief of the Daily Sun, said his role was not to "protect" readers. ( 37 ) Cornell president Frank H. T. Rhodes joined his colleagues at Duke and Michigan in defending the paper's decision. ( 38 )

The University of Montana's paper, the Montana Kaimin, also used the First Amendment to defend its publication of the ad. The editor contended that it was not the paper's place to "decide for the campus community what they should see." ( 39 ) The University of Georgia's paper the Red and Black, expressed the hope that publishing the ad would affirm America's unique commitment to "allowing every opinion to be heard, no matter how objectionable, how outright offensive, how clearly wrong that opinion may be." After the ad appeared the paper's editor defended the decision by describing it as "a business decision," arguing that "if the business department is set up to take ads, they darn well better take ads." Given the juxtaposition of these two explanations, there was, as Mark Silk, an editorial writer for the Atlanta Constitution pointed out, something dubious about "this high - minded claim." ( 40 )

After an extensive debate Washington University's Student Life decided to run the ad. When the ad appeared in the paper, Sam Moyn, the opinion editor, was responsible for conveying to the university community the reasoning behind the staff ' s "controversial action." The editors, he wrote, conceived of this as a free - speech issue: "The abridgement of Mr. Smith ' s rights endangers our own.'' ( 4 1) The St. Louis


P ost Dispatch defended the students' actions. Declaring the ad "offensive, provocative and wrong," i t praised the student newspaper' s courage to print it and stated that its actions strengthened the cause of freedom of speech. ( 42 ) The University of Arizona also depicted its actions as protecting the First Amendment. The editor in chief, Beth Silver, proclaimed that the mission of student newspapers is "to uphold the First Amendment and run things that are obviously going to be controversial and take the heat for it." ( 43 ) This attitude -- we have to do what is right irrrespective of the costs -- was voiced by a number of papers. Ironically, it echoed a theme frequently voiced by the deniers themselves: We will tell the truth, the consequences notwithstanding.

At Ohio State University the decision - making process was complex. The Lantern ' s advertising policy is in the hands of a publications committee comprising faculty, students, editorial board members, and the paper's business manager. ( 44 ) University policy requires committee approval before acceptance of an ad designating a religious group. The committee voiced five to four to reject CODOH ' s submission. ( 45 ) But the story did not end there. Enjoined by the committee's decision from running the ad, the Lantern ' s editor, Samantha G. Haney, used her editorial powers to run it as an op - ed piece, explaining that the paper had an "obligation" to do so. (46) This decision gave Smith added legitimacy and saved him the $1,134 it would have cost to place a full - page ad in the paper. ( 47 )

A lengthy editorial explaining the Lantern's decision condemned Bradley Smith and his cohorts as "racists, pure and simple" and the ad as "little more than a commercial for hatred." Nonetheless the newspaper had to publish it because it could not only "run things that were harmless to everyone." ( 48 ) Haney and her staff rejected the suggestion that they turn to the Ohio State History Department to "pick apart" the ad fact by fact. That, they explained, might suggest that the ad had some "relevancy" and some "substance," which they were convinced it did not. Given that one of the rationales the Lantern offered for publishing the article was that "truth will always outshine any lie," its refusal to ask professional historians to elucidate how the ad convoluted historical fact seemed self - defeating. ( 49 ) It seemed to reflect an understandable reluctance to accord denial legitimacy. There is no better example of the fragility of reason than the conclusion by these editorial boards that it was their obligation to run an ad or an op - ed column that, according to their own evaluation, was totally lacking in relevance or substance.

In contrast to the position adopted by James Duderstadt at the

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University of Michigan, Ohio State's president, Gordon Gee, attacked the decision to give Smith space in the newspaper, declaring the deniers' arguments "pernicious" and "cleverly disguised" propaganda that enhanced prejudice and distorted history. ( 50 )

When this issue was being debated at Ohio State, a CBS reporter came to that campus to film a segment on Holocaust denial for a network show on hatred and extremism in the United States. Alerted in advance to the pending controversy, the cameras were conveniently present when the editor received a call from Smith congratulating her for running the ad and standing up for the principles of free speech and free press. When Haney hung up, the television reporter, who was standing nearby, asked how she felt. She turned and somewhat plaintively observed that she thought she had been had.

Not all the papers subscribed to the First Amendment argument; indeed, some explicitly rejected it. The University of Tennessee's Daily Beacon dismissed the idea that not running the ad harmed the deniers' interests: It was not "censorship or even damaging.'' ( 51 ) Pennsylvania State University's Daily Collegian, which had been one of the first to receive an ad from Smith, denied that the issue was one of free speech. After seeing student leaders and numerous individuals on campus inundated with material by deniers, the paper reasoned that those behind the ad had sufficient funds to propagate their conspiracy theory of Jewish control without being granted space in the paper. ( 52 )

In an eloquent editorial the Harvard Crimson repudiated Smith's claim to a free - speech right to publish his ad. To give CODOH a forum so that it could "promulgate malicious falsehoods" under the guise of open debate constituted an "abdication" of the paper's editorial responsibility. ( 53 ) The University of Chicago Maroon agreed that while the deniers "may express their views," it had "no obligation at anytime to print their offensive hatred." ( 54 )

The argument that not publishing the ad constituted censorship was not only a misinterpretation of the First Amendment but disingenuous. The editorial boards that reached this decision ignored the fact that they all had policies that prevented them from running racist, sexist, prejudicial, or religiously offensive ads. (Some of the papers in question even refuse cigarette ads.) How could they square their "principled" stand for absolute freedom of speech with policies that prevented them from publishing a range of ads and articles? Why was Bradley Smith entitled to constitutional protection while an ad for an X - rated movie, Playboy, the KKK, or Marlboros was not? Recognizing this inconsistency, some of the boards tried to reconcile these two seemingly con


tradictory positions by adopting a stance that drew them even further into the deniers' trap. They argued that Holocaust denial was not antisemitic and therefore not offensive. The Cornell Daily Sun editorial board determined that the "ad does not directly contain racist statements about Jewish people." ( 55 ) Valerie Nicolette, the Sun's managing editor, told the Chronicle of Higher Education that the editors had evaluated the ad based on their standards of "obscenity and racism" and decided that it passed. ( 56 ) When a group of Jewish students at Duke met with the editorial board of the Duke Chronicle to protest the running of the ad, they were told that the paper's policy was not to run any ad that was "racist or contained ethnic slurs" but that this ad did not fall into that category. ( 57 )

Andrew Gottesman, who vigorously argued that he could not condone "censorship" of Smith's advertisement and whose Michigan Daily published its ringing denunciation of Holocaust denial under Justice Hugo Black's interpretation of the First Amendment, admitted that there were ads he would not run in the paper. This ad, however, did not deserve to be "banned from the marketplace of ideas, like others might be." Among those he would ban were a Ku Klux Klan announcement of Iynching or a beer ad with a woman holding a beer bottle between her breasts. ( 5 8) For Gottesman keeping such sexist and racist ads out of the paper would not constitute censorship; keeping Smith's out would. When Washington University's Student Life published the ad, an editorial explained that it did so in the interest of preventing "freedom of ideas from disappearing from its newspapers." ( 59 ) Yet the same paper includes the following policy statement on its advertising rate card: "Student Life reserves the right to edit or reject any advertisement which does not comply with the policies or judgment of the newspaper. ( 60 )

The claim that the rejection of the ad constituted censorship also revealed the failure of editorial staffs and, in certain cases, university presidents to think carefully about what their papers did regularly: pick and choose between subjects they covered and those they did not, columns they ran and those they rejected, and ads that met their standards and those that did not. The Daily Tar Heel, the paper of the University of North Carolina, proclaimed that as soon as an editor "takes the first dangerous step and decides that an ad should not run because of its content, that editor begins the plunge down a slippery slope toward the abolition of free speech." ( 6 1) What the Tar Heel failed to note was that newspapers continuously make such choices. As Tom Teepen, the editor of the Atlanta Constitution's editorial page, observed, "Running a newspaper is mainly about making decisions, not


about ducking them." ( 62 ) In fact the Duke Chronicle, whose editor had wondered how newspapers founded on the principles of free speech and free press could "deny those rights to anyone," had earlier rejected an insert for Playboy and an ad attacking a fraternity. ( 63 )

While some papers justified their decision by arguing that the ad was not antisemitic and others leaned on the censorship argument, an even more disconcerting rationale was offered by many papers. They argued that however ugly or repellent Smith's "ideas," they had a certain intellectual legitimacy. Consequently it was the papers' responsibility to present these views to readers for their consideration. Those editors who made this argument fell prey to denial's attempt to present itself as part of the normal range of historical interpretation. ( 64 ) That they had been deceived was evident in the way they described the contents of the ad. The editor in chief of the Cornell Daily Sun described the ad as containing "offensive ideas." ( 65 ) The Sun argued that it was not the paper's role to "unjustly censor advertisers' viewpoints" however "unpopular or offensive." ( 66 ) In a similar vein the University of Washington Daily defended giving Smith op - ed space because the paper must constitute a "forum for diverse opinions and ideas." ( 67 ) Ironically, six weeks earlier, when it rejected the ad, it had described Smith's assertions as "so obviously false as to be unworthy of serious debate." ( 6 8) The paper insisted that the op - ed column it eventually published was different because it was Smith's "opinion" and did not contain the "blatant falsehoods" of the ad. In the column Smith asserted that for more than twelve years he has been unable to find "one bit of hard evidence" to prove that there was a plan to "exterminate" the Jews, and that the gaschamber "stories" were "allegations" unsupported by "doeumentation or physical evidence." ( 69 )

The Michigan Daily engaged in the same reasoning. It would not censor "unpopular views" simply because readers might disagree with them. ( 70 ) In a show of consistency, two weeks after Smith's ad appeared the Daily supported the decision by Prodigy, the computer bulletin board, to allow subscribers to post Holocaust denial material. Prodigy they contended, was similar to a newspaper, and like a newspaper it must be a " forum for ideas.'' ( 71 ) In another suggestion that Smith's views were worthy of debate, the editor in chief of the Montana Kaimin argued that "this man's opinions, no matter how ridiculous they may be need to be heard out there." ( 72 ) According to the editor in chief of Washington University's Student Life, the board voted to run the ad because "we didn't feel comfortable censoring offensive ideas." ( 73 )

The Ohio State Lantern's explanation of why it let Smith have his


" public say" despite the fact that i t condemned Smith and CODOH as " racist, pure and simple," was more disturbing than the decision itself. The Lantern argued that it was "repulsive to think that the quality, or total lack thereof, of any idea or opinion has any bearing on whether it should be heard." ( 74 ) It is breathtaking that students at a major university could declare repulsive the making of a decision based on the "quality" of ideas. One assumes that their entire education is geared toward the exploration of ideas with a certain lasting quality. This kind of reasoning essentially contravenes all that an institution of higher learning is supposed to profess.

The e ditors of Washington University's St u dent Life dem on strate d a similar disturbing inconsistency. They dismissed Smith's claim to be engaged in a quest for the truth, describing him as someone who "cloaks hate in the garb of intellectual detachment." They believed that Smith was posing as a "truth seeker crushed by a conspiratorial society." ( 75 ) Given their evaluation of Smith, his tactics, and the way conspiracy theorists have captured the imagination of much of American society, what followed was particularly disconcerting. Notwithstanding all their misgivings, the editors decided that they must give "Mr. Smith the benefit of the doubt if we mean to preserve our own rights." In an assertion typical of the confused reasoning that student papers nationwide displayed on this issue, the Student Life editors acknowledged that they could have suppressed Smith's views "if we attributed motives to him that contradict his statements. But we cannot in good conscience tell Mr. Smith that we 'know' him and his true intentions." Was not the fact that he was denying a historical fact about whose existence there is no debate among any reput able scholars indicative of something sign ificant? The editorial board had concluded that "if we refused Mr. Smith's advertisement, we could censor anyone based on ulterior motives that we perceive them to harbor."' (7 6 ) At what point would the board feel it was appropriate to make a decision based on the objective merits of the information contained in the ad?

In this instance what the paper considered to be ulterior motives is what scholars call coming to a conclusion based on a wide variety of facts, including historical data. In giving Smith the "benefit of the doubt," the editors fell prey to the notion that this was a rational debate. They ignored the fact that the ad contained claims that completely contravened a massive body of fact. They transformed what the Harvard Crimson described as "vicious propaganda" into iconoclasm.

The most controversial interpretation about precisely what this ad represented was expressed by the Duke Chronicle. In a column justify -

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ing the paper's decision to run the ad, Ann Heimberger contended that "Revisionists are ... reinterpreting history, a practice that occurs constantly, especially on a college campus." ( 77 ) In a private meeting with Jewish student leaders on the Duke campus, the editors reiterated this argument. The students were told that the ad was neither racist nor antisemitic but was part of an ongoing "scholarly debate." ( 78 ) The Duke editorial board viewed the advertisement more as "a political argument than as an ethnic attack." ( 79 ) In editorials, articles, and interviews, those at helm of the Duke Chronicle repeatedly referred to Holocaust denial as "radical, unpopular views," and "disturbing ideas" and argued that the ad was not a "slur" but an "opinion." ( 80 ) By doing so they not only clung to their First Amendment defense, they gave the ad historical and intellectual legitimacy.

The Chronicle's acceptance of the ad and the editor's defense of having done so elicited two reactions. Bradley Smith, quite predictably, praised Heimberger's column as "fantastic" and an example of sound reasoning. (81) A less laudatory response came from the Duke History Department, which, in a unanimously adopted statement, asserted that the ad aimed to "hurt Jews and to demean and demonize them." It was particularly vehement about Heimberger's contention that the ad was nothing more than a reinterpretation of history. The department observed that the "scholarly pretensions" of the ad were effective enough to deceive Heimberger so that she believed the ad's claims were part of the "range of normal historical inquiry." The statement continued:

If the ad convinced Heimberger, one can only imagine its impact on individuals who have had less exposure to history and critical thinking.

There were, of course, those college newspapers that had no problem evaluating the ad's intellectual value. The Harvard Crimson repudiated the idea that the ad was a "controversial argument based on questionable facts." In one of the most unequivocal evaluations of the ad, the Crimson declared it "vicious propaganda based on utter bullshit that has been discredited time and time again." More than "moronic and false," it was an attempt to "propagate hatred against Jews." ( 83 ) The editorial board of the University of Pennsylvania ' s Daily Pennsylvanian


argued that "running an ad with factual errors that fostered hate" was not in the best interests of the paper. ( 84 )

The MIT Tech simply decided that it would not accept an ad that it knew "did not tell the truth." ( 85 ) For the Brown Daily Herald the ad was "a pack of vicious, antisemitic lies" parading as "history and scholarship." ( 86 ) The Daily Ne x us, the publication of the University of California at Santa Barbara, refused the ad because of its "blatant distortions of truth and its offensive nature." The paper described receiving the ad itself and the more than one thousand dollars to print it as "chilling." ( 87 ) The Dartmouth Review, no stranger to controversy, also rejected the ad. It acknowledged that by so doing it was denying "someone a forum through which to speak to the paper's readership" but explained that it had a "bond of trust" with the public, which expected it to abide by "standards of accuracy and decency." Accepting an ad "motivated by hatred and informed by total disregard to the truth" would be to violate that trust. ( 88 ) The Chicago Maroon saw no reason why it should run an ad whose "only objective is to offend and incite hatred." ( 89 ) The Yale Daily News "simply" let Smith know that it found the ad "offensive." ( 90 )

Some of the papers that ran the ad did so on the basis of what may be called the light - of - day, defense, a corollary of the free - speech argument: In the light of day, truth always prevails over lies. Neeraj Khemlani of the Cornell Sun believed that by running the ad he had done the Jewish people a favor -- reminding them that there were a "lot of people out to get [them]," which was something they needed to know. ( 9 1) This attitude is reminiscent of the concept of "saving the Jews (or women, African Americans, or any other potentially vulnerable group) despite themselves. Michael Gaviser, business manager of the Daily Pennsylvanian, decided to run the ad because of his belief that Smith was a "dangerous neo - Nazi" of whom the public had to be aware. (His decision was reversed by the editorial board.) ( 92 )

A number of the nation's most prominent national papers echoed the light - of - day position. A Washington Post editorial rejected the freedom - of - the - press argument but accepted the light - of - day rationale. Acknowledging that college newspapers had no obligation to accept the ads, it argued that it was "bad strategy" automatically to "suppress" them. What the ad needed was the "bracing blast of refutation." The Post did not seem to consider the possibility that an article fully analyzing the ad would have served the same purpose. ( 93 ) In an archetypal deniers move Smith cited the Post's editorial as proof that the paper believed it both "ethical and permissible" to debate the "Holocaust story. ( 94 ) He made the same claim about a New York Ti m es editorial that

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left it up to each newspaper to decide whether to publish Smith's "pseudo - scholarly" and "intellectualy barren" tract. ( 95 )

The Rutgers Daily Targum contended that publication of the ad constituted a means of defeating Smith. The editors argued that "you cannot fight the devil you cannot see." ( 96 ) Exposing Smith's views through publication of his ad could thwart his objectives. ( 97 ) The Targum correctly understood that the First Amendment did not apply -- ("CODOH was wrapped itself so tightly in the First Amendment it borders on suffocation.") -- and the claim to be engaged in historical investigation was dismissed as "a sham." Nonetheless it chose to reprint Smith's ad in full on the editorial page, surrounding it with three op - ed pieces and an editorial, all of which attacked the ad's contents. In addition, an editors' note introducing the column noted that the ad had originally been rejected by the paper's business section because of "its false content and antisemitic nature." The editorial board argued that despite all this it was necessary to print the advertisement in full because, "more than anything else, [it] makes it painfully obvious that a clear and present danger exists." ( 98 ) Reiterating this point in a letter to the New York Times, Targum editor Joshua Rolnick argued that publishing the ad in its entirety was the best way of "mobilizing the community in opposition to its hateful ideas." ( 99 )

The Targum's decision to print the ad as a column and surround it with dissenting opinion won it the editorial praise of the New York Times: "The editors thus transformed revulsion into education.'' (100) Nevertheless there is reason to question that decision. First of all it saved Smith the approximately five hundred dollars it would have cost to purvey his extremist arguments. The paper proudly proclaimed that it had "not accepted any payment" from him, as if the acceptance of money made them accomplices. In fact it was Smith, Rolnick acknowledged, who had "encouraged" him to run it as an op - ed piece. Smith may well have recognized that, the dissenting articles notwithstanding the full text of his ad was likely to win converts to his cause even as it mobilized some people against him. Given the space the Daily Targum devoted to the topic, a lengthy analytical piece quoting heavily from the ad and demolishing it point by point would have served the same purpose and given Smith less of a chance to lay out his "argument." Some wonder what was the danger of allowing Smith his say, particularly when surrounded by articles that firmly and swiftly refuted him. But the Daily Targum had given Smith just what he wanted: They made him the other side of a debate. Although it may not have been evenly balanced, although more room may have been given to the articles that


surrounded his, and although editorials may have condemned him, he had nonetheless been rendered a point of view. (101) Smith seems to be acutely cognizant of the efficacy of even bad publicity. That may well be why, when a rally at Rutgers denounced Holocaust revisionism and his ad, he declared himself "grateful and delighted" that the rally was held. (102)

In the spring of 1992 Smith began to circulate a second ad that was essentially a reprint of an article from the Journal of Historical Review by Mark Weber. The article, entitled "Jewish Soap," blamed the postwar spread of the rumor that the Nazis made Jews into soap on Simon Wiesenthal and Stephen Wise -- a claim that has no relationship to reality. Echoing the first ad, it charged that historians of the Holocaust have "officially abandon[ed] the soap story" in order to "save what's left of the sinking Holocaust ship by throwing overboard the most obvious falsehoods.'' (103) The point of this second effort, Smith acknowledged, was to submit a piece that was thoroughly "referenced." (104) The ad was submitted with a cover letter that claimed that the original ad had been rejected by a number of papers because it was not "sourced." In contrast, every "significant claim" in the second ad was backed up by sources. (105) Entitled "Falsus in Uno, Falsus in Omnibus [False in one thing, false in all] ... The 'Human Soap' Holocaust Myth," the essay on soap was preceded by a statement citing Roman law: If a witness could not be "believed in one thing, he should not be believed in anything.'' (1 06 )

Most universities that received the second ad, including those who had accepted the first, rejected it out of hand. When it was submitted to the Oh i o State Lantern, the editor immediately refused it, observing that "the only news value in this is that Bradley Smith is approaching schools again." Having been burned once, the editor seemed far more cognizant of Smith's motives. "The fact that it is Holocaust Remembrance Week indicates that he's in to ruffle some feathers and stir up trouble again." (107) The arguments about the First Amendment and censorship no longer seemed to apply. ##

At the University of Texas the deliberations about the second ad

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were directly linked to what had occurred with the first ad. The editor of the Daily Texan, Matthew Connall y, had wanted to run the first. (108) However, after familiarizing himself with the "group behind the ad," he reversed his decision. "They were not only showing a disregard for the truth but they were doing it with malicious intent." (1 09 ) The Texas Student Publication Board (TSPB), which has ultimate authority over the paper's advertising and financial affairs, supported Connally and voted to reject the ad. After hearing Connally's arguments, TSPB member Professor John Murphy, who initially voted in favor of running the ad, decided to oppose it.

But that was not the end of the story at Texas. In April the paper received Smith's second ad. Though the Daily Texan's editorial board was firmly against running it, they quickly discovered that the decision was not in their hands: They were told by the TSPB that they must run it. 'We do not want to do this. But we're being told we must follow orders," a member of the editorial board told me sadly. (110) This time Professor Murphy emerged as the ad's most vociferous supporter. According to the Houston Chron ic le, Murphy, supported by a number of other UT faculty members, argued that the paper needed to publish "divergent and unpopular opinion.'' (111) Facing a situation in which it would be forced to publish something it "detested," the editoral board considered leaving all the pages blank except for the ad. (They were told that since this would affect advertising revenues, they did not have the authority to do so.)

The ad was scheduled to run on Holocaust Memorial Day, Yom HaShoah, 1992. Students opposed to the ad discovered that the internal regulations of the TSPB prohibited the newspaper from printing opinion ads unless all persons cited in those ads had granted permission to be quoted. I was among the scholars quoted in the ad. Fortuitously, I was scheduled to visit the campus to deliver a lecture on Holocaust denial the day before the ad's scheduled publication. When I indicated my opposition to being cited in the ad, an emergency meeting of the TSPB board was called to discuss the matter. I informed the board that I had not given my permission to be quoted in the ad and was opposed to being associated with it. I pointed out that the ad specifically violated their own regulations. ### Despite my objections and my announcement that I would explore the possibility of legal remedies should the ad be


published, the TSPB voted to run it, postponing publication for a few days so that my name could be dropped and a rebuttal prepared. Two days later the university's legal counsel suggested that because individuals quoted in the ad had protested -- by this time other professors mentioned in the ad had joined the protest -- the ad should be dropped. (11 2 )

The TSPB then voted to reject the ad. But the story did not end here. In February 1993 the TSPB compelled the paper to accept an ad promoting a video exposé of the gas chambers by a CODOH member claiming to be a Jew. Based on advertisements and articles by this young man, the video apparently contains the same recycled arguments deniers have been making for years. Though the editorial board and the university president opposed the ad because it was "deceptively rigged," the TSPB ran the ad. Five of the six students on the TSPB and one of its faculty members voted for the ad. Both working professionals voted against it.

During this period students were not the deniers' only campus targets. For more than two years -- not for the first time -- deniers had tried to insinuate themselves into the scholarly arena by finding ways to place Holocaust denial on the agenda of organizations of professional historians. They sought to force these groups to treat denial as a legitimate enterprise. In the spring of 1980 all members of the Organization of American Historians (OAH) received a complimentary copy of the first issue of the Journal of H i storical Rev1ew. It was quickly revealed that the IHR had purchased the OAH's twelve thousand member mailing list. Some OAH members protested the sale of the list to this neo - Nazi group. Others argued that to deny anyone the right to purchase the list would be to abridge intellectual freedom. The executive secretary of the OAH proposed to resolve the issue by inviting a panel of " well - qualified historians" to analyze the Journal and evaluate it based on the "credentials of the contributors and the use of evidence." He would then transmit this evaluation to the OAH executive board so it could decide how to treat the matter.

Lucy Dawidowi c z, a fierce critic of the OAH response, wondered what those historians would evaluate: "Perhaps that the neo - Nazis did not have proper academic credentials or that they failed to use primary sources?'' (113) Carl Degler, a past president of the OAH, defended the suggestion that the OAH should sponsor an analysis of the Jou r nal. He

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argued that once historians begin to consider the "motives" behind historical research and writing, "we endanger the whole enterprise in which the historians are engaged." Following the same pattern as the student editors who described the contents of the denial ad as opinions views, and ideas, he described the articles contained in the Journal as "bad historical writing." Given the Journal's contents and its publisherés identity, Degler's categorization of it as bad history was described by Dawidowi c z as a ''travesty.'' (11 4 )

A far - less - ambiguous position was adopted by the editors of the Journal of Modern History, when the Liberty Lobby bought its subscription list and sent out antisemitic material. The journal's editors sent a letter of apology to its subscribers acknowledging that an "antisemitic hate organization" had obtained its mailing list. It "repudiate[d] and condemn[ed] the propaganda" that readers had received and apologized that both the readers and the academic discipline had been "abused in this thoroughly scurrilous manner.'' (115)

Another attempt to force professional historians to treat Holocaust denial as a legitimate enterprise began in 1990, when members of various university history departments began to receive letters soliciting support for "Holocaust revisionism." That same year the American Historical Association's (AHA) annual meeting was disrupted by pickets calling for recognition of a book charging Gen. Dwight Eisenhower with consciously causing the death of a million German POWs at the end of the war. + The AHA issued a statement noting that 1995 marked the fiftieth anniversary of the defeat of Nazism and calling on scholars to "initiate plans now to encourage study of the significance of the Holocaust.'' (116)

The AHA statement referred to the Holocaust but did not explicitly say that the Holocaust was a fact of history. According to the then - president of the AHA, William Leuchtenburg, it did not want to "get into the business of certifying what is and is not history." + + Moreover, he believed that for a group of historians to say there had been a Holocaust was tantamount to "an organization of astronomers saying there is a m oon.'' (117)


The press, he believed, would simply ignore such a statement. In December 1991 the AHA unanimously adopted a statement deploring the "attempts to deny the fact of the Holocaust" and noting that "no serious historian questions t hat the Holocaust took place.'' (11 8 ) Leuchtenburg opposed allowing deniers a table at the convention because the AHA was a professional organization and they were not professionals. It would be the equivalent of the AMA allowing quacks to hawk miracle cures at its meetings.

The OAH was also a target of the deniers. In November 1991 the OAH's exe c utive committee agreed to allow its newsletter to publish a call by the IHR's Journal of Historical Review for "revisionist" papers. This action was taken after David Thelen, the editor of the OAH's scholarly journal, the Journal of American History, refused to list articles by deniers because it was the responsibility of an academic publication to "make judgments on the quality of scholarship.'' (11 9 ) He felt it was harder to refuse them space in the association's newsletter because it contained both scholarly and nonscholarly information. Joyce Appleby, OAH president, protested the executive committee's decision to accept the announcement in the OAH Newsletter. "This is not a question of respecting different points of view but rather of recognizing a group which repudiates the very values which bring us together," Appleby wrote. It was the responsibility of a professional organization to make "professional judgments" and, Appleby asserted, "these people are not professionals and to allow them to advertise is to legitimate them. " (120)

Mary Frances Berry, a former president of the OAH and a history professor at the University of Pennsylvania, disagreed with Appleby. She compared the debate within the OAH to campus codes against "hate speech," to which she objected. Her primary concern was "guaranteeing civil liberties for everyone." She argued that since the OAH did not have a general policy regarding advertisements it would accept or reject, it was obligated to accept everything it received. (121) The next issue of the OAH Newsletter contained a series of letters regarding the decision to include the ad and Appleby's dissent. A group of prominent historians, including Thelen and Berry, wrote in support of the inclusion of denial announcements. (1 22 ) They argued that however "abhorrent the goals of the Journal of Historical Review, the constitutional pAnciple of free speech as well as the OAH's commitments to freedom of expression and the search for histo ri cal truth demanded that the ad be printed. In an apparent attempt to "balance" their support of the ad, they su gg ested a va ri ety of strategies for dealing with the future efforts

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by the Journal of Historical Review and other deniers to place ads in OAH publications. One idea was that the OAH "pressure" the deniers' journal to abide by international standards of scholarship, including that experts in appropAate fields evaluate articles submitted to the journal. Given the way they handle doeuments and data, it is clear that deniers have no interest in scholarship or reason. Most are antisemites and bigots. Engaging them in reasoned discussion would be the same as engaging a wizard of the Ku Klux Klan in a balanced and reasoned discussion of Af ri can Americans' place in society. But on some level Carl Degler was right: Their motives are irrelevant. Some may truly believe the Holocaust a hoax -- just as hundreds of antisemites believed the Protocols genuine. This does not give the contents of their pronouncements any more validity or intellectual standing. No matter how sincerely one believes it, two plus two will never equal five. Among the histodans' other suggestions was that a "truth - in - advertising" group be created to unmask the misleading claims in denial notices and announcements and that this group insist that their exposure be published along with the deniers' claims. But such a suggestion would imply that a debate was being conducted by mainline historians and "revisionists." (12 3 ) The histo ri ans' ideas, offered in the name of an attempt to resolve a situation that confounds many academics, played directly into the deniers' hands. Given the response of such eminent teachers of history, it is not surprising that the Daily Northwestern, Northwestern University's student newspaper, writing in support of inviting Arthur Butz to debate his "unorthodox view" of the Holocaust, declared that "even outrageous and repugnant theoAes sometimes deserve a forum.'' (1 24 ) Students emulated exactly what these professors had done. They had elevated what the Harvard Crimson had properly characterized as "utter bullshit" to the level of a theory deserving of a forum. After the IHR's announcement appeared, the executive board voted to establish a policy henceforth to exclude such advertisements and announcements from the newsletter. There was significant debate within the OAH's leadership on this matter, and the decision to exclude denial ads in the future passed by one vote. (1 25 )

Writing in support of Appleby, the Los Angeles Times provided an interesting slant to the argument. It pointed out that the First Amendment guaranteed freedom of association as well as freedom of speech. As a result the OAH had the right to "exclude fake historians from its ranks.'' (1 26 ) It was probably the most appropriate and possibly the most creative citation of the First Amendment du ri ng this entire debate.



The responses to Holocaust denial by both students and faculty graphically demonstrate the susceptibility of an educated and privileged segment of the American population to the kind of reasoning that creates a hospitable climate for the rewriting of history. There were a variety of failures here. All of them are sobering indicators of the ability of Holocaust denial to gain legitimacy. There was a failure to understand the true implications of the First Amendment. There was also a failure by student editors to recognize that their high - minded claims about censorship were duplicitous, given their papers' policies of rejecting a broad range of ads and articles. In fact, campus policies are often more restActive than those of the commercial press.

There was a failure to look at the deniers' own history and to understand what they represented. The observation of the Ohio State Lantern Angs hauntingly in my ears: "It is repulsive to think that the quality, or total lack thereof, of any idea or opinion has any beaAng on whether it should be heard.'' (1 27 ) It is a response likely to make professors nationwide cringe. But, as we have seen, professors also showed their confusion on this matter.

Most disturbing was the contention voiced by students, faculty members, and university presidents that however ugly, the ad constituted an idea, opinion, or viewpoint -- part of the broad range of scholarly ideas. However much they disassociated themselves from the content of the ad, the minute they categorized it as a "view," they advanced the cause of Holocaust denial. That students failed to grasp that the ad contravened all canons of evidence and scholarship was distressing. But those at the helm sometimes also failed to grasp that the ad was not advocating a radical moral position but a patent untruth. Writing in the Cornell Daily Sun, President Frank Rhodes couched the discussion in terms of freedom of the press, arguing, "Free and open debate on a wide range of ideas, however outrageous or offensive some of them may be, lies at the heart of a university community." Rhodes was positing that Holocaust denial should be considered an idea worthy of inclusion in the arena of open debate. (1 28 )

This assault on the ivory tower of academe illustrated how Holocaust denial can permeate that segment of the population that should be most immune to it. It was naive to believe that the "light of day" can dispel lies, especially when they play on familiar stereotypes. Victims of racism, sexism, antisemitism, and a host of other prejudices know of light's limited ability to discredit falsehood. Light is barely an antidote when people are unable, as was often the case in this investigation, to differentiate between reasoned arguments and blatant falsehoods.

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Most sobering was the failure of many of these student leaders and opinion makers to recognize Holocaust denial for what it was. This was particularly evident among those who argued that the ad contained ideas, however odious, worth of discussion. This failure suggests that correctly cast and properly camouflaged, Holocaust denial has a good chance of finding a foothold among coming generations.

This chapter ends where it began. Given the fact that even the papers that printed the ad dismissed Smith's claims in the most derogatory of terms -- absurd, irrational, racist, and a commercial for hatred -- one might argue that the entire affair had a positive outcome. Rarely did the ad appear without an editorial or article castigating Holocaust denial. Students were alerted to a clear and present danger that can easily take root in their midst. Courses on the Holocaust increased in number. One could argue that all this is proof that CODOH's attempt to make Holocaust denial credible backfired.

My assessment is far more pessimistic. It is probably the one issue about which I find myself in agreement with Bradley Smith. Many students read both the ad and the editorials condemning it. Some, incluing those who read neither but knew of the issue, may have walked away from the controversy convinced that there are two sides to this debate: the "revisionists" and the "establishment historians." They may know that there is tremendous controversy about the former. They may not be convinced that the two sides are of equal validity. They may even know that the deniers keep questionable company. But nonetheless they assume there is an "other sid e." That is the most frightening aspect of this en tire matter.


* Among the papers that accepted it, either as an ad or an op - ed column, were those of the University of Arizona, Cornell, Duke, the University of Georgia, Howard, the University of Illinois at Urbana - Champaign, Louisiana State, the University of Michigan, the University of Montana, Northwestern, Ohio State, Rutgers, Vanderbilt, Washington University, and the University of Washington.

Among those colleges rejecting the ad were Berkeley, Brown, the University of California at Santa Barbara, the University of Chicago, Dartmouth, Emory, Georgetown, Harvard, the University of Minnesota, the University of North Carolina, the University of Pennsylvania, Purdue, Rice, the University of Southern California, the University of Tennessee, the University of Texas (Austin), UCLA, the University of Virginia, the University of Wisconsin (Madison), and Yale.

** The memorial stone at Auschwitz lists the number of victims of the camp as 4 million. Research now indicates that the number of people who died in the Auschwitz/Birkenau gas chambers was between 1.5 and 2 million, of whom 85 to 90 percent were Jews.

*** The papers discussed in this chapter function as private newspapers. The courts have broadly defined their editorial discretion to accept or reject ads. In situations of "state action," where a state university administration controls the newspaper's content, the courts may prohibit content - based rejection of the ads. Discretion of Student Editors to Accept or Reject Holocaust Re v isionist Ad v ertisements (ADL Legal Affairs Dept., Feb. 1992).

# In 1931, in Near v . Minnesota, the Supreme Court struck down a state attempt to gag a paper's freedom to publish "malicious, scandalous or defamatory" material. Fred W. Friendly, M innesota Rag (New York, 1981).

## The Tu ft s Daily was the only paper that decided to run portions of the ad. Its editors voiced the opinion that it was necessary to run the ad so that readers could "fully comprehend" the deniers arguments and then make "informed judgments" and engage in "active dialogue" about «complex issues." They reached that conclusion despite their conviction that Smith's views had li ttle if any "legitimacy" and were filled with "hateful sentiments and ideas that defile the memories of the millions killed in World War II . To have rejected it would have "unilaterally censored" the campus community from the issue. Tufts joined other campuses in falling prey to the light - of - day argument: In search of a principled stand, they gave Smith exactly the exposure he sought.

### At the meeting one of the editors of the paper, an African Ame ri can, stood up and said that while he could not personally know what it felt like to lose so many of one's coreligionists in the Holocaust, he "knew" the pain of slavery. He would fight anyone's attempt to deny that. Consequently he felt obligated to fight this attempt at denial.

He also turned to Murphy and said that he understood that one of Murphy's objections was that it was infantilizing to prevent the students from deciding on the contents of the ad themselves. He wondered if it was not equally infantilizing to tell an entire editonal board to publish something whose publication it uniformly opposed.

+ The deniers have cited these contentions, which have been subjected to se ri ous histo ri cal and methodological c ri tiques, to support their claims that whatever atrocities the Nazis committed, those committed by the Allies were worse.

++ The full text of the resolution read "As we approach the fiftieth anniversary of the downfall of the Nazi regime in 1995, the Ame ri can Historical Association calls attention to the need to initiate plans now to encourage study of the significance of the Holocaust. To that end the association will make available the names of experts on the history of the event." Chronicle of Higher Education, January 8, 1992.

Chapt er 10. The Batde for the Campus

1. Cited in Nat Hentoff, "An Ad that Offends: Who's On First?" Progressive, May 12, 1992, p. 12.

2. Smith was featured on a variety of national television shows and in major newspapers, including the New York Times, Dec. 23, 1991.

3. Louisiana State Daily Reveille, Apr. 7, 1992.

4. Holocaust Revisionism: Reinventing the Big Lie (ADL Research Report), p. 9.

5. ADL memorandum, Feb. 26, 1987.

6. IHR Newsletter, Jan., Mar., and Sept. 1987; Jan. and Nov. 1988; Feb. 1989.

7. Undated letter, Bradley Smith to Friends, 5 pp (1988?).

8. Prima Facie (Feb. 1985), p. 1.

9. Spearhead (Mar. 1985), p. 20.

10. Christian News, Apr. 25, 1987.

11. Spotlight, Apr. 11, 1988.

12. Christian News, Sept. 14, 1987.

13. University of Nebraska Sower, Nov. 17, 1989, p. 10.

14. Centre Daily Times (State College, Pa.) Apr. 1, 1989.

15. Bradley Smith to Kathy Lachenauer, editor in chief, Stanford Daily, June 16, 1989.

16. Bradley Smith to Rabbi Ari Cartun, June 19, 1989.

17. Laird Wilc ox, "The Spectre Haunting Holocaust Revisionism," Revisionist Letters (Spring 1989), p. 10.

18. Ibid.

19. Visalia Times - Delta, Sept. 13, 1990; Daily Illini, June 16, 1992.

20. New York Times, Dec. 23, 1991.

21. Bradley R. Smith, "The Holocaust Story: How Much is False? The Case for Open Debate," Daily Northwestern, Apr. 4, 1991.

22. New York Times, Nov. 12, 1989.

23. Arno Mayer (Princeton University), Yehuda Bauer (Hebrew University), Marvin Hier (Simon Wiesenthal Center), Raul Hilberg (University of Vermont), and myself (Emory University).

24. Smith, "The Holocaust Story."

25. The first paper to run the lengthy ad was the Daily Northwestern, April 4, 1991.

26. Michigan Daily, Oct. 24, 1991.

27. Detroit Free Press, Oct. 25, 1991.

28. Michigan Daily, Oct. 25, 1991.

29. Detroit Free Press, Oct. 25, 1991.

30. Michigan Daily, Oct. 28, 1992.

31. In recent years a series of First Amendment controversies have captured the attention of the American public. The most highly publicized was the debate over the funding by the National Endowment for the Arts of an exhibit of Robert Mapplethorpe photography. Edward de Grazia, Girls Lean Back Everywhere: The Laws of Obscenity and the Assault on Genius (New York, 1992); Natalie Robins, Alien Ink: The FBI's War on Freedom of Expression (New York, 1992); Rodney A. Smolla, Free Speech in an Open Society (New York, 1992).

32. New York Times, Jan. 15, 1992.

33. Kathleen M. Sullivan, "The First Amendment Wars," New Republic, Sept. 28, 1991, p. 39.

34. Duke Chronicle, Nov. 5, 1991.

35. Ibid, Nov. 7, 1991.

36. Cornell Daily Sun, Nov. 18, 1991; Associated Press newswire, Nov. 19, 1991.

37. Rutgers Daily Targum, Nov. 26, 1991, p. 6.

38. Chronicle of Higher Education, Nov. 27, 1991.

39. Havre, Mont., Daily News, Apr. 29, 1992. One of the defenders of the Kaimin's publication of the ad was the programming adviser of the university's student organization. He had also been instrumental in arranging for a visit by David Duke to the Missoula campus. He argued that ads such as Smith's and visits such as Duke's challenge "people to not react emotionally and react rationally." Montana Kaimin, May 5, 1992.

40. Atlanta Cons titution, Mar. 23, 1992.

41. Student Life, Feb. 18, 1992.

42. St. Lou is Post D is patch, Feb. 23, 1992.

43. University of Washington Daily, Apr. 27, 1992.

44. Columbus D is patch, Jan. 22, 1992.

45. Ohio Jew is h Chronicle, Jan. 30, 1992, p. 1.

46. Ibid., Jan. 30, 1992.

47. Columbus D is patch, Jan. 22, 1992.

48. Ohio State Lantern, Jan. 24, 1992, p. 8.

49. Ibid.

50. Ibid. Tufts's dean of students also strongly dissented from the idea that Smith was protected by the First Amendment: "Individuals have a right to their own ideas but not to be published on another individual' s or group's printing press." Tufts Daily, Apr. 8, 1992.

51. University of Tennessee Daily Beacon, Apr. 27, 1992.

52. Penn State Daily Collegian, Mar. 31, 1989.

53. Harvard Crimson, Dec. 10, 1991, p. 2.

54. University of Ch ic ago Maroon, Feb. 28, 1992.

55. Cornell Daily Sun, Nov. 20, 1991.

56. Chron ic le of Higher Education, Nov. 27, 1991.

57. Mark Livingston to Sam Cramer, Nov. 6, 1991.

58. Michigan Daily, Oct. 28, 1991.

59. Student Life, Feb. 21, 1992.

60. Ibid., Feb. 25, 1992.

61. Daily Tar Heel, cited in Atlanta Constitution, Nov. 28, 1991, p. H1.

62. Ibid.

63. Duke Chronicle, Nov. 5, 1991, p. 9, and Nov. 7, 1991, pp. 1, 3.

64. Resolution adopted by the Duke University History Department, Nov. 8, 1991, and reprinted in Duke Chronicle, Nov. 13, 1991.

65. Rutgers Daily Targum, Nov. 6, 1991, pp. 1, 6 (italics added).

66. Cornell Daily Sun, Nov. 18, 1991 (italics added).

67. University of Washington Daily, Apr. 27, 1992 (italics added).

68. Ibid., Mar. 4, 1992.

69. Ibid., Apr. 27, 1992.

70. Ibid., Oct. 18 and 28, 1991.

71. Michigan Daily, Nov. 11, 1991.

72. Havre, Mont., Daily News, Apr. 29, 1992.

73. St. Lou* Post Dispatch, Feb. 22, 1992.

74. Ohio State Lantern, Jan. 24, 1992.

75. Student Life, Feb. 18, 1992.

76. Ibid.

77. Duke Chronicle, Nov. 5, 1991, p. 9.

78. Livingston to Cramer, Nov. 6, 1991.

79. Duke Chronicle, Nov. 7, 1991, p. 3.

80. Ibid., Nov. 5, 1991, p. 9, and Nov. 7, 1991, pp. 1, 3 (italics added).

81. Ibid., Nov. 21, 1991, p. 3.

82. Ibid., Nov. 13, 1991, p. 7 (Italics added).

83. Harvard Crimson, Dec. 10, 1991, p. 2.

84. Ibid.

85. Boston Jew*h Advocate, Mar. 6, 1992.

86. Brown Daily Herald, Dec. 11, 1991.

87. University of California at Santa Barbara Daily Nexus, Apr. 29, 1992.

88. Dartmouth Review, Nov. 6, 1991, p. 9.

89. University of Chicago Maroon, Feb. 28, 1992.

90. Chronicle of Higher Education, Nov. 27, 1991.

91. Jew is h Voice (Dec. 1991).

92. Chronicle of Higher Education, Nov. 27, 1991.

93. Washington Post, Dec. 21, 1991.

94. Smith, "Falsus in Uno, Falsus in Omnibus .. . The 'Human Soap' Holocaust Myth," addendum to Smith, undated letter sent to campus papers.

95. New York Times, Jan. 15, 1992.

96. Rutgers Daily Targum, Dec. 3, 1991, p. 10.

97. Michigan Daily, Dec. 3, 1991, p. 3.

98. Rutgers Daily Targum, Dec. 3, 1991, p. 10.

99. New York Times, Dec. 30, 1991.

100. Ibid., Jan. 15, 1992.

101. Rutgers Daily Targum, Dec. 3, 1991, pp. 10 -11.

102. Ibid. , Dec. 6, 1991, p. 5.

103. Tufts Daily, April 2 1, 1992.

104. Ibid.

105. Smith, undated letter sent to campus papers with text of second ad.

106. Smith, "Fal sus in Uno, Falsus in Omnibus."

107. Ohio State Lantern, Apr. 29, 1992.

108. M ic higan Daily, Nov. 26, 1991.

109. Houston Chronicle, Dec. 11, 1991.

110. Meeting with members of Daily Texan editorial board, Apr. 28, 1992.

111. Houston Chronicle, Apr. 24, 1992, pp. 25A, 31A; Daily Texan, Apr. 24, 1992, p. 5.

112. Bay City, Tex., Daily Tr i bune, Apr. 30, 1992.

113. "Journal of Historical Review," OAH Newsletter (July 1980), pp. 14 -15; Dawidowic z, "Lies About the Holocaust," p. 37.

114. Carl N. Degler, "Bad H is tory," Commentary, June 1981, p. 17.

115. Ibid.

116. Chronicle of Higher Education, Dec. 11, 1991.

117. Duke Chron ic le, Apr. 27, 1992.

118. Chronicle of Higher Education, Jan. 8, 1992.

119. Ibid. , Dec. 11, 1991.

120. OAH Newsletter (Nov. 1991); Chron*le of Higher Education, Dec. 11, 1991, pp.9 -10.

121. Chro nic le of Higher Education, Dec. 11, 1991, p. 10.

122. Other signatories included Dan Carter, Cullom Davis, Sara Evans, Linda Gordon, Lawrence Levine, and Mary Ryan. OAH Newsletter (Feb. 1992), p. 5.

123. Ibid.

124. Daily Northwestern, Mar. 5, 1991, p. 6.

125. OAH Newsletter (Feb. 1992), p. 4. Conversation wit h Joyce Appleby, December 1992.

126. Los Angeles Times, Dec. 23, 1991.

127. Ohio State Lantern, Jan. 24, 1992, p. 8.

128. Carlos C. Huerta, "Revisionism, Free Speech and the Campus," Midstream, Apr. 1992, p. 10.

This is a part of Deborah Lipstadt's book, Denying the Holocaust -- The Growing Assault on Truth and Memory, 1993, Penguin. We offer this document in relation with a trial due to take place in the first days of Year 2000 in London, where British historian David Irving is suing Mrs. Lipstadt for defamation, --to allow the public to take freely cognizance of the sentences and words used by the author.

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