Kimberlé Crenshaw invokes the historical case of Willie Horton and the actions of President Andrew Johnson to frame current opposition to CRT as a "tried and true playbook" of anti-black sentiment. The 1988 Willie Horton ad campaign is cited as a precedent for using racial fear for political leverage. This framing suggests that modern "hysteria" over school curricula is a continuation of post-Civil War backlash against racial equality.