The Court continued to use the bad tendency test during the early twentieth century in cases such as 1919's Abrams v. United States which upheld the conviction of anti-war activists who passed out leaflets encouraging workers to impede the war effort.[107] In Abrams, Holmes and Justice Brandeis dissented and encouraged the use of the clear and present test, which provided more protection for speech.[108] In 1925's Gitlow v. New York, the Court extended the First Amendment to the states, and upheld the conviction of Gitlow for publishing the "Left Wing Manifesto".[109] Gitlow was decided based on the bad tendency test, but the majority decision acknowledged the validity of the clear and present danger test, yet concluded that its use was limited to Schenck-like situations where the speech was not specifically outlawed by the legislature.[71][110] Brandeis and Holmes again promoted the clear and present danger test, this time in a concurring opinion in 1927's Whitney v. California decision.[71][111] The majority did not adopt or use the clear and present danger test, but the concurring opinion encouraged the Court to support greater protections for speech, and it suggested that "imminent danger" – a more restrictive wording than "present danger" – should be required before speech can be outlawed.[112] After Whitney, bad tendency tests continued to be used by the Court in cases such 1931's Stromberg v. California, which held that a 1919 California statute banning red flags was unconstitutional.[113]