And, the “bootstrap” – where a later majority or even plurality of Justices just adopts some earlier thin analysis as canon. Neat:
There is no force in respondent’s argument that the constitutional limitations implicit in the history of the Sedition Act apply only to Congress, and not to the States. It is true that the First Amendment was originally addressed only to action by the Federal Government, and  that Jefferson, for one, while denying the power of Congress “to controul the freedom of the press,” recognized such a power in the States. See the 1804 Letter to Abigail Adams quoted in Dennis v. United States, 341 U.S. 494, 522, n. 4 (concurring opinion). But this distinction was eliminated with the adoption of the Fourteenth Amendment and the application to the States of the First Amendment’s restrictions. See, e.g., Gitlow v. New York, 268 U.S. 652, 666; Schneider v. State, 308 U.S. 147, 160; Bridges v. California, 314 U.S. 252, 268; Edwards v. South Carolina, 372 U.S. 229, 235.