Whatever you think of the expulsion of US president Donald Trump’s press secretary, Sarah Huckabee Sanders, from Red Hen restaurant in Lexington, Virginia on June 22, you’d likely approve of Hollywood businesses denying service to Leni Riefenstahl, Adolf Hitler’s close collaborator, in 1938.

Last week, restaurant owner Stephanie Wilkinson inflamed or inspired the nation—depending on who you ask—by telling Sanders to leave her establishment. “For Wilkinson…the decision to passively and peacefully protest the Trump administration—notably, at the end of a week in which the news cycle was dominated by reports of undocumented children at the US-Mexico border getting separated from their parents by the US government—felt more urgent and personal than protecting the cause of polite civil discussion,” writes Lila MacLellan for Quartz at Work.

With this move, Wilkinson became part of an American business tradition of not welcoming the mouthpieces of disapproved politicians. Red Hen joined the ranks of a few notable Hollywood movie studios, which refused to welcome Riefenstahl, Hitler’s propagandist, who visited the states before World War II.

Leni Riefenstahl goes to Hollywood

According to a Dec. 1, 1938 article in the United Press, the German filmmaker and actress was not welcomed to tour Warner Bros. and other production companies. Universal Studio denied Riefenstahl entry although she’d acted in its movie SOS Iceberg five years earlier. Twentieth Century Fox said Riefenstahl could tour its studio, but unlike other “distinguished visitors,” the request for entry would have to come from the German consulate to be approved, said the studio.

Phil Selznick, a Hollywood nightclub owner, also turned Riefenstahl and her party away, refusing reservations for the German and 11 others. (The 1938 article doesn’t specify which club she was trying to get into.) Riefenstahl’s manager Ernst Jaeger apparently insisted that she was only in town for the “scenery” and not political reasons. But she was widely rebuffed nonetheless and reportedly spent most of her time in Hollywood denying she was Hitler’s girlfriend or an agent of his regime.

Only one big studio rolled out the red carpet for Riefenstahl: the one belonging to Walt Disney, allegedly a Nazi sympathizer. According to animator Art Babbit, who worked closely with Disney, the studio head often attended Nazi party meetings in Hollywood before World War II. Disney himself welcomed the Nazi filmmaker in 1938. He gave her a tour of his studios, shared sketches for the upcoming film Fantasia, and held a private screening of her latest work, Olympia, a documentary on the 1936 Olympics. In the 2008 biography Leni, by Steven Bach, Riefenstahl is said to have been heartened by Disney’s invitation, claiming it was “gratifying to learn how thoroughly proper Americans distance themselves from the smear campaigns of the Jews.”

Although Riefenstahl was big in pictures long before she met Hitler, she became truly famous after the Nazi leader commissioned her work for his own political ends. Reportedly, she initially rebuffed Hitler’s commissions but relented when he promised unlimited resources and full artistic license. She ended up creating one of the best-remembered propaganda films of all time, 1934 documentary film on Nazi party rallies, The Triumph of the Will. The US Holocaust Memorial Museum Holocaust Encyclopedia entry on Riefenstahl says, “Triumph of the Will, with its evocative images and innovative film technique, ranked as an epic work of documentary filmmaking, and is widely regarded as one of the most masterful propaganda films ever produced. It won several awards, but forever linked the film’s subject, National Socialism, with its artist, Riefenstahl.”

A history of business activism

Prior to Riefenstahl’s arrival in Hollywood, the Anti-Nazi League printed a full-page ad in the trade papers denouncing her. This tactic was used in 1936 by the same organization to denounce the visit of Vittorio Mussolini, son of Benito Mussolini, who led Italy’s Nationalist Fascist Party. Young Mussolini was “picketed” by Hollywood upon arrival, according to the United Press.

Sometimes it’s the star who snubs an establishment, however, for its insensitivity. In 1951, actress Grace Kelly was at the popular Stork Club in Manhattan and noticed nightclub employees weren’t serving singer and activist Josephine Baker, presumably because Baker was a black woman. Kelly and Baker walked out of the club arm in arm, two stars making a statement. In that case, the Stork Club was refusing Baker based on the color of her skin, not for her political views—and that’s now illegal.

Denying a person service because of what they are, on a protected ground—like race, religion, or sexual identity— is distinct from refusing to do business with someone because of a political opinion or position. That’s not necessarily a legal issue, though it might be a societal one. David Cole, ACLU national legal director, told The Washington Post (paywall) he disagrees with the Red Hen’s actions but the restaurant owner was within her rights to deny Sanders service. “I think it’s wrong, but under most jurisdictions’ laws, it has not been made illegal,” he said.

As the majority decision in the recent Masterpiece Cakeshop US Supreme Court case noted, a business can refuse to bake a cake with a message or shape it finds offensive. It cannot, however, deny service on the general grounds that it disapproves of who the customer is, or the person’s identity. The Colorado baker in this particular case refused to bake a wedding cake for a gay couple’s marriage on the grounds he opposes homosexuality. His refusal violated Colorado civil rights laws. But, as the court decision noted, three other Colorado bakers who had refused to bake a bible-shaped cake with decoration explicitly stating “homosexuality is a sin,” because they found the message offensive, were not found to be in violation of the law. Ultimately, Masterpiece Cakeshop was decided for the Colorado baker on very narrow grounds: because the Colorado Civil Rights Commission members had expressed hostility to the baker’s religion and not based on an approval of the baker’s refusal to do business based on a sexual orientation he deemed distasteful.

After Sanders’ expulsion from Red Hen, some argued that one’s work and person are separate matters and that we must, above all else, remain polite in civil society, whatever our political opinions. The restaurant’s refusal to serve Trump’s spokesperson sparked a national debate about the limits of politesse. For many people who feel mostly helpless about impacting the direction of politics, and hopeless about Trump’s actions, Wilkerson’s move proved individuals can make some kind of difference, if only by causing a moment of discomfort for someone in power.

Whether or not you agree that such actions are meaningful, Riefenstahl’s case more clearly demonstrates why there might be limits to the directive to play nice in society, and why even people who consider themselves polite may choose to deny service to someone whose views seem too rude to excuse if we’re in the position to do so.