22 Harv. Blackletter L. J. 25 (2006)
Confronting Racists at the Bar: Matthew Hale, Moral Character, and Regulating the Marketplace of Ideas

handle is hein.journals/hblj22 and id is 29 raw text is: CONFRONTING RACISTS AT THE BAR:
MATTHEW HALE, MORAL CHARACTER,
AND REGULATING THE MARKETPLACE
OF IDEAS
Jason 0. Billy*
I. INTRODUCTION
In 1998, Matthew Hale graduated from Southern Illinois Law School
and passed the Illinois bar examination in July of that year.1 Nevertheless,
the Inquiry Panel for the Supreme Court of Illinois's Committee on Char-
acter and Fitness, in a 2-1 decision, denied Hale admission to the practice
of law.2 Because of his racist beliefs, the Panel found that Hale did not
possess the requisite character and fitness necessary for admission.3
At the time of his application to the Illinois bar, Hale was not only a
recent law school graduate, but also the Pontifex Maximus (Supreme
Leader) of an organization called the World Church of the Creator. Hale's
church was founded in 1973 by Ben Klassen, a Canadian-born former mem-
ber of the Florida legislature. The organization admires Adolf Hitler and
Germany's movement of National Socialism; however, it believes that
Hitler's ideas regarding racial superiority should have been applied to
include all whites, as opposed to only Germans.4 Hale and his church op-
pose violence and the forcible overthrow of the American government.
Nevertheless, the Inquiry Panel of the Committee on Character and Fit-
ness noted, Mr. Hale stated in his interview with us that if his organiza-
tion would gain power by peaceable means it would call for the deporta-
tion of the Jews, blacks and others whom his church refers to as 'mud
races.'-
* J.D., Harvard Law School, 2005; B.A., Columbia University, 2001. I would like to
thank Professor Andrew Kaufman for his insightful comments and suggestions. I
would also like to thank the staff of the Harvard BlackLetter Law Journal, especially
Kevin K. Anderson, for their editorial assistance. Lastly, I would like to express my
gratitude to my friends and family for their support and encouragement.
1. See Mark Schauerte, Illinois Seeks to Deny a Law License to Vocal Racist, ST. Louis POST-
DISPATCH, Feb. 22, 1999, at Al.
2. In re Hale, COMM. OF CHARACTER & FITNESS (Ill. App. Ct. 1998), reprinted in GEOFFREY
C. HAZARD ET AL., THE LAW AND ETHICS OF LAWYERING 875 (3d ed. 1999).
3. Id. at 875-76, 883-84.
4. Id. at 876.
5. Id.

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