June 21 in History

Thirteen thousand soldiers surrounded a Kyoto temple at dawn, and within hours, the most powerful warlord in Japan was dead. Akechi Mitsuhide, one of Oda Nobunaga’s most trusted generals, launched his betrayal at Honno-ji on June 21, 1582, attacking while Nobunaga rested with a guard of fewer than a hundred men. Nobunaga fought with a spear until wounded, then retreated into the burning temple and took his own life rather than be captured. Nobunaga had spent two decades unifying Japan through a combination of military genius, ruthless diplomacy, and technological innovation. He was the first Japanese commander to use massed firearms effectively in battle, and he had systematically crushed the Buddhist warrior monks and rival daimyo who stood between him and national unification. By 1582, he controlled roughly a third of Japan and seemed poised to complete the conquest. Mitsuhide’s motives remain one of Japanese history’s great mysteries. Some historians point to personal grievances, including alleged public humiliation by Nobunaga. Others suggest political calculation or possible connections to the imperial court. Whatever drove him, his reign as usurper lasted only thirteen days. Toyotomi Hideyoshi, another of Nobunaga’s generals, force-marched his army back from a western campaign and destroyed Mitsuhide’s forces at the Battle of Yamazaki on July 2. Hideyoshi seized the political vacuum left by both men, eventually completing Japan’s unification and launching invasions of Korea. The chain of succession from Nobunaga through Hideyoshi to Tokugawa Ieyasu produced 250 years of peace under the Tokugawa shogunate, but the path there ran directly through one general’s betrayal at a burning temple.

A single vote in a New Hampshire convention hall completed the most audacious political experiment of the eighteenth century. When delegates in Concord voted 57 to 47 to ratify the United States Constitution on June 21, 1788, they provided the ninth state needed to make the document the supreme law of the land. The margin was razor-thin, and the outcome was far from certain until the final hours of debate. The Constitution had emerged from a sweltering summer in Philadelphia the year before, where delegates originally tasked with revising the Articles of Confederation had instead scrapped them entirely. The resulting document proposed a radical framework: a strong central government with separated powers, a bicameral legislature, and an executive branch headed by a single president. Anti-Federalists across the country mounted fierce opposition, arguing the Constitution gave too much power to a distant federal government and lacked a bill of rights. New Hampshire’s ratification triggered a constitutional countdown. Though the document was now technically in effect, the new government could not function without Virginia and New York, the two largest holdout states. Virginia ratified four days later; New York followed in July, swayed partly by Alexander Hamilton, James Madison, and John Jay’s Federalist Papers. The first Congress convened in March 1789, and George Washington took the oath of office the following month. The promise of a bill of rights proved essential to securing ratification in several states. James Madison introduced the first ten amendments in Congress in 1789, and they were ratified by December 1791. What began as a compromise to win over skeptics became the foundation of American civil liberties, protecting freedoms that the original Constitution had deliberately left unaddressed.

Twelve jurors delivered a verdict that rewrote American criminal law. On June 21, 1982, John Hinckley Jr. was found not guilty by reason of insanity for the attempted assassination of President Ronald Reagan, an outcome that stunned the public and triggered immediate calls for legal reform. Hinckley had shot Reagan and three others outside the Washington Hilton on March 30, 1981, in an attempt to impress actress Jodie Foster. The trial exposed deep tensions in American attitudes toward mental illness and criminal responsibility. Under federal law at the time, the prosecution bore the burden of proving the defendant was sane beyond a reasonable doubt. Hinckley’s defense team presented extensive psychiatric testimony showing he suffered from severe depression and erotomania, an obsessive belief that Foster was in love with him. The prosecution’s own psychiatric experts could not agree on his mental state. Public outrage was immediate and bipartisan. Polls showed that more than 80 percent of Americans disagreed with the verdict. Within three years, Congress passed the Insanity Defense Reform Act of 1984, which shifted the burden of proof to the defendant and narrowed the legal definition of insanity. More than thirty states followed with their own reforms, and several eliminated the insanity defense entirely. Hinckley spent 35 years confined to St. Elizabeths Hospital in Washington, D.C., before his unconditional release in 2022. The case permanently changed how American courts handle the intersection of mental illness and criminal culpability, making the insanity defense far harder to invoke and even harder to win.

Five Supreme Court justices finally put a definition on something the law had been chasing for decades. In Miller v. California, decided June 21, 1973, Chief Justice Warren Burger established a three-part test for obscenity that remains the standard today: whether the average person applying community standards would find the work appeals to prurient interest, whether the work depicts sexual conduct in a patently offensive way, and whether the work lacks serious literary, artistic, political, or scientific value. The case arose from a mass mailing campaign by Marvin Miller, a California pornography distributor who sent unsolicited brochures advertising adult books and films to random addresses. One landed in the mailbox of a restaurant manager and his mother, who complained to police. Miller was convicted under California’s obscenity statute, and his appeal eventually reached the Supreme Court. Before Miller, the legal standard for obscenity had shifted repeatedly. The 1957 Roth decision established that obscene material lacked First Amendment protection but offered a vague definition. The 1966 Memoirs case added requirements so stringent that prosecution became nearly impossible. The Miller Court deliberately simplified the test and, crucially, replaced a national standard with community standards, allowing local juries to decide what crossed the line in their own communities. The decision drew sharp dissent from Justices Douglas and Brennan, who argued the First Amendment protected all expression and that no workable definition of obscenity was possible. Half a century later, their skepticism looks prescient: the internet has made community standards nearly meaningless when any content is accessible everywhere simultaneously.

Scotland’s Parliament voted 99 to 17 to repeal a law that had silenced a generation of LGBTQ+ people without ever sending anyone to prison. Section 28, enacted by Margaret Thatcher’s government in 1988, prohibited local authorities and schools from "promoting" homosexuality or teaching its "acceptability as a pretended family relationship." The repeal on June 21, 2000, made Scotland the first part of the United Kingdom to strike down the provision. Section 28 emerged from a moral panic of the late 1980s, when conservative politicians accused left-wing councils of using taxpayer money to promote gay lifestyles. The actual trigger was a children’s book called "Jenny Lives with Eric and Martin" found in a London school library. Though the law never led to a single prosecution, its chilling effect was enormous: teachers avoided discussing homosexuality entirely, school counselors declined to support LGBTQ+ students, and local libraries pulled books with gay themes. Repeal in Scotland did not come easily. Brian Souter, the Stagecoach transport tycoon, funded a private referendum that drew more than a million responses, with 86 percent opposing repeal. The Scottish Executive dismissed the poll as unrepresentative, and First Minister Donald Dewar pushed the legislation through despite organized opposition from religious leaders and tabloid campaigns. England and Wales did not repeal Section 28 until November 2003, more than three years after Scotland led the way. The law’s legacy persists in a generation of LGBTQ+ Britons who grew up in schools where their identities were treated as unspeakable, a silence whose effects researchers continue to document in higher rates of mental health difficulties among those educated during the Section 28 era.

Liu Bei died on June 10, 223 AD, in Baidicheng, present-day Chongqing, after a devastating military defeat that left his Shu Han kingdom weakened and his lifelong dream of restoring the Han dynasty unfulfilled. Born in 161 AD in Zhuo County, in what is now Hebei Province, Liu Bei claimed descent from the Han imperial family, a lineage that gave him political legitimacy in a period when the Han dynasty was collapsing under the weight of internal corruption, regional warlordism, and the Yellow Turban Rebellion. He began his career as a minor warlord with few resources, relying on personal charisma and the loyalty of his sworn brothers Guan Yu and Zhang Fei, relationships immortalized in the fourteenth-century novel "Romance of the Three Kingdoms." His early decades were marked by repeated defeats and retreats as he struggled to establish a territorial base against far more powerful rivals. His fortunes changed when he recruited the strategist Zhuge Liang in 207 AD. Zhuge Liang's "Longzhong Plan" outlined a strategy for Liu Bei to seize the provinces of Jing and Yi, then use them as a base for reunification. The strategy worked through 219 AD, when Liu Bei declared himself king of Hanzhong and controlled significant territory in central and southwestern China. But the alliance with Sun Quan of Wu collapsed when Wu forces killed Guan Yu and seized Jingzhou. Liu Bei launched a massive retaliatory campaign against Wu in 222, despite Zhuge Liang's objections, and suffered a catastrophic defeat at the Battle of Xiaoting. The defeat destroyed the bulk of Shu Han's military strength. Liu Bei retreated to Baidicheng and died there, entrusting his young son and the kingdom to Zhuge Liang in one of the most famous deathbed scenes in Chinese historical literature.