Michael O'Flanagan States in April 1925 to help Sinn Féin contest a number of by-elections. That summer he was suspended from clerical duties and forbidden to say mass because of his nationalist activities and anti-clerical speeches he had made in America. In March 1926, the Sinn Féin ard fheis narrowly defeated de Valera's proposal to enter the Free State Oireachtas if the Oath of Allegiance were removed. O'Flanagan sided with the majority. De Valera left to found Fianna Fáil, which eclipsed Sinn Féin at the June 1927 election. O'Flanagan remained with the reduced Sinn Féin. Bishop Coyne died in July 1926, but
Clinton Fein Court for the Northern District of California made a divided decision on the lawsuit. Fein filed an Supreme Court appeal, which he won in 1999. In June 1999, the U.S. government sent Fein an order to reveal a user of Annoy.com's e-card service. Earlier, in April 1999, the University of Houston tried unsuccessfully to obtain the website's records. The government later ordered Fein to stop discussing details of this investigation, its existence or its application. In "United States v. ApolloMedia", Fein argued that this gag order violated the First Amendment and the statutory requirement that it have a definite duration.