Alice Catherine Evans in 1917 and published her work in the "Journal of Infectious Diseases" in 1918. She was met with skepticism, particularly because she was a woman and did not have a Ph.D. She warned that raw milk should be pasteurized to protect people from various diseases. During the 1920s, scientists around the world made the same findings, and eventually, "Brucella" was confirmed as the disease that caused what was then known as undulant fever and Malta fever. Her findings led to the pasteurization of milk in 1930. As a result, the incidence of brucellosis in the United States was significantly reduced.
True threat the case, the Court noted that "a threat must be distinguished from what is constitutionally protected speech." The Court recognized that "uninhibited, robust, and wideopen" political debate can at times be characterized by "vehement, caustic, and sometimes unpleasantly sharp attacks on government and public officials." In light of the context of Watts' statement - and the laughter that it received from the crowd - the Court found that it was more "a kind of very crude offensive method of stating a political opposition to the President" than a "true threat." In so holding, the Court established that there is a