activism by Black musicians. Simone helped to increase awareness of Black claims to civil rights as well as helped to raise funds for civil rights organizations. Simone did not think of herself as involved in the movement, only encouraging activists as an artist from the stage. Yet eventually, she became “driven by civil rights and the hope of [B]lack revolution.” 83 The notorious Birmingham church bombing spurred Simone to write songs of a political nature. In September 1963, white supremacists bombed the Sixteenth Street Baptist Church in Birmingham, Alabama, killing four girls and injuring twenty-two others. The church was targeted because it had become a center for Black civil rights activism in Birmingham. “According to Simone, ‘Mississippi Goddam’ erupted out of [her] right after she  heard about the church bombing.” 84 In the lyrics, Simone expressed anger and despair, and “rejected the notions that race relations could change gradually, that the South was unique in terms of discrimination, and that African Americans could or would patiently seek political rights.” 85 She also stridently criticized interracial activism as a viable means of achieving civil rights. 86 She later remarked that the song was her “first civil rights song,” written because she “suddenly realized what it was to be [B]lack in America in 1963.” 87 Simone went on to write “many songs . . . in which she dramatically commented on and participated in—and thereby helped to recast—[B]lack activism in the 1960s.” 88 Before and after writing “Mississippi Goddam,” Simone buttressed civil rights organizations and their efforts by performing at benefit concerts in the North and the South. 89 Simone supported national, mainstream organizations including the Student Nonviolent Coordinating Committee, the Congress of Racial Equality, and the National Association for the Advancement of Colored People. Her concerts raised thousands of dollars for organizations, far more than what could be raised by other performers. 90 C. The Costs of Black Musical Activism From slavery through modern times, opposition to musical activism has included criminal punishment, government surveillance, and extra-legal violence. During slavery, bans on musical expression were enacted to diminish 83. N INA S IMONE & S TEPHEN C LEARY , I P UT A S PELL ON Y OU : T HE A UTOBIOGRAPHY OF N INA S IMONE 90–91 (1992). 84. Id. at 89–90. 85. Feldstein, supra note 82, at 1349. 86. Id. 87. S IMONE & C LEARY , supra note 83, at 89–90. 88. Feldstein, supra note 82, at 1350. 89. Id. at 1361. 90. Id. at 1360.
3-D ENNIS (D O N OT D ELETE ) 7/8/2016 9:15 AM 42 L AW AND C ONTEMPORARY P ROBLEMS [Vol. 79:29 movements, and in modern times investigation and prosecution of musical artists along with general surveillance of musicians has served as a means for social control. Finally, those who utilized musical expression in support of social movements frequently elicited threats of, or experienced actual, physical violence from opponents.