Proto-Cointelpro

"Yet, in all its activities, the government offered the rationale of 'national security,' claiming that internal dangers were sufficient to discard constitutional guarantees. In responding to criticism over the prosecution of the Christian Front, Hoover had retorted: 'It took only 23 men to overthrow Russia.' Administration reasoning in World War II set a precedent for far more massive government spying during the Cold War, particularly against civil rights organizations and opponents of the Vietnam conflict. The very Smith Act used in 1944 against domestic fascists was used with far more severity against Communists during the Cold War, the law's scope only being limited by the Supreme Court in 1957."

In a 2017 Daily Beast article, Justus D. Doenecke looks at civil liberties under Franklin Roosevelt.