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In 1977, a neo-Nazi group planned to march in Skokie, Illinois, in a largely Jewish neighborhood that was home to many Holocaust survivors. It was believed that the march would be disruptive, and the city refused to allow it. The American Civil Liberties Union came to the Nazis' support, and in 1978 a high court upheld the Nazis' right to march, on the grounds that the public display of the Nazi flag is a constitutionally protected free expression. After winning the court battle, the Nazis decided to march in Chicago's Marquette Park instead. In 1987, a Holocaust Monument and Museum was opened in Skokie. On the night of its dedication, the monument was desecrated with swastikas.

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