The poem was part of a satirical performance. The performance was deemed protected speech, although the content of the poem by itself would have been a violatio

The poem was part of a satirical performance. The performance was deemed protected speech, although the content of the poem by itself would have been a violation of a libel law (§ 103) explicitly protecting foreign heads of state that is being abolished as a consequence of this precedent. He's also still very much able to "make a living off of his comedy". His "Schmähkritik" (the title of the piece as well as the crime reciting the poem would constitute) was just a single one-off performance on a publicly funded TV show.