Communists were the enemy during the Cold War. On appeal from the Court of Appeals for the District of Columbia, the Supreme Court ruled in 1958 that regulations denying passports to Communists were invalid. But rather than expel these perceived enemies, the government wanted to keep them in the country. The Bar Association of DC chimed in with the 1960 article entitled "Committee on UnAmerican Activities, Passport Control" in the Bar Journal.

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