Section III: The Statutes That Survived — A Comparative Analysis
The Espionage Act of 1917 — The Most Durable Survivor
While the Sedition Act of 1918 was repealed and the Smith Act was judicially narrowed into effective disuse, the Espionage Act of 1917 (Pub. L. No. 65-24, 40 Stat. 217, 1917), codified principally at 18 U.S.C. §§ 793–798, remains the most actively enforced national security statute in federal law. Its durability reflects a key structural feature: it targets the disclosure and transmission of information relating to national defense — conduct, not speech. The Act does not criminalize the political ideas of those who disclose classified information; it criminalizes the act of disclosure itself.
The Act's application in the modern era has focused primarily on government insiders who leak classified information — intelligence analysts, military personnel, contractors — and has generated consistent controversy about its scope and proportionality. The cases have nonetheless produced convictions:
- Chelsea Manning, an Army intelligence analyst who transmitted approximately 750,000 classified military and diplomatic documents to WikiLeaks, was convicted of multiple Espionage Act counts and sentenced to 35 years in 2013 (United States v. Manning, 2013). Her sentence was commuted by President Obama in 2017.
- Reality Winner, an NSA contractor who leaked a single classified report on Russian election interference, was sentenced to 63 months in federal prison — the longest Espionage Act sentence at that time for an unauthorized disclosure (United States v. Winner, 2018).
- Jack Teixeira, a Massachusetts Air National Guard airman who posted hundreds of classified intelligence documents in a Discord chat server, was charged in April 2023 and pleaded guilty in 2024 (United States v. Teixeira, 2023).
- Former President Donald Trump was charged in June 2023 with 31 counts of willful retention of national defense information under the Espionage Act following his handling of classified documents at Mar-a-Lago. The charges were ultimately dismissed after his election victory; however, the indictment itself demonstrated that Espionage Act prosecution extends to the highest levels of government.
The Espionage Act's critics — including many civil libertarians and press freedom advocates — argue that it was designed for traditional espionage and is being misapplied to journalists' sources and whistleblowers. The statute contains no public interest defense and makes no distinction between the spy and the whistleblower. This critique is ongoing; the statute, whatever its policy defects, remains fully operative and actively enforced.
18 U.S.C. §§ 2383 and 2384 — Insurrection and Seditious Conspiracy
Two statutes in the same chapter as the Smith Act have proven far more durable precisely because they target conduct — conspiracy and insurrection — rather than speech. Section 2383, titled 'Rebellion or insurrection,' imposes up to ten years in prison and permanent disqualification from federal office on any person who 'incites, sets on foot, assists, or engages in any rebellion or insurrection against the authority of the United States or the laws thereof, or gives aid or comfort thereto' (18 U.S.C. § 2383, 2018). Section 2384, titled 'Seditious conspiracy,' imposes up to twenty years on any two or more persons who 'conspire to overthrow, put down, or to destroy by force the Government of the United States, or to levy war against them, or to oppose by force the authority thereof' (18 U.S.C. § 2384, 2018).
These statutes survived the post-Brandenburg era for a straightforward reason: they describe criminal agreements and overt acts, not speech. A conspiracy requires an agreement between at least two people to commit an illegal act and an overt act in furtherance of the agreement. The First Amendment does not protect conspiratorial agreements any more than it protects contract murder. Brandenburg's 'imminent lawless action' test governs the boundary of protected speech, not the boundary of criminal conduct.