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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.”{61} 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.”{68} 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 gas-chamber “stories” were “allegations” unsupported by “documentation 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 it 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 editors of Washington University’s Student Life demonstrated 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 reputable scholars indicative of something significant? 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.”{76} 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 justifying 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.