When the case got to supreme court they lost. ... It was the case that Oliver Wendell Holmes enunciated<span> the "</span>clear and present danger<span>" </span>doctrine<span> and used the analogy that " free speech would not protect a man in falsely shouting fire in a theatre, and causing panic."</span>
The declaration was never recognized by either the United States or Spain. Later in 1898, Spain ceded the Philippines to the United States in the 1898 Treaty of Paris that ended the Spanish–American War.
