In 1925, the Taft Court laid the groundwork for the incorporation of many of the guarantees of the Bill of Rights to be applied against the states through the Fourteenth Amendment. In "Gitlow v. New York", the court by a 6–2 vote with Taft in the majority, upheld Gitlow's conviction on criminal anarchy charges for advocating the overthrow of the government; his defense was freedom of speech. Justice Edward T. Sanford wrote the court's opinion, and both majority and minority (Holmes, joined by Brandeis) assumed that the First Amendment's Free Speech and Free Press clauses were protected against infringement by the states.