In Stromberg v. California, 283 U.S. 359 (1931), the defendant was charged under a California statute that prohibited displaying a red flag for any of three purposes: (1) as a symbol of opposition to organized government; (2) as an invitation to anarchistic action; or; (3) as an aid to seditious propaganda. Stromberg, 283 U.S. at 361. The trial court instructed the jury that they could convict the defendant if they found that she displayed a flag for any one of the three purposes. See id. at 363. The jury returned a general verdict of conviction. See 283 U.S. at 367-368. The Supreme Court held that the first clause of the statute was an unconstitutional restriction of free speech. See 283 U.S. at 368-370. The Court concluded that the conviction must be reversed, because it was impossible to determine from the general verdict whether the defendant was convicted under the unconstitutional clause or one of the other two clauses. See id.