> that if speech has the effect of creating a real-life threat >(To be clear, the point wasn't that Chaplinsky is the be-all-end-all, just that the concept of

> that if speech has the effect of creating a real-life threat >(To be clear, the point wasn't that Chaplinsky is the be-all-end-all, just that the concept of "hate speech," where the consequences of some speech make it unworthy of free speech protections, is not a recent invention.) Yes, but those consequences must be imminent and unlawful. The point of Chaplinsky isn't that it's a real life in the moment affront to civility so offensive that it's bound to cause a fight. Planned Parenthood v. American Coalition of Life Activists is about specific threats, e.g. "I'm going to specifically kill you". Both examples of non-protected speech are under totally different doctrines (I forget how far back the specific credible threat doctrine goes and what the real name for it is but it's really old, older than planned parenthood) that were more or less condensed into the "imminent lawless conduct" test established in (Brandenbyug). It's going to be very hard for anything that is published in an asynchronous medium that isn't a direct call to lawless action by someone who can credibly get people to pull it off to fail the test because in order for the lawless action to happen people must do things that would be premeditated crimes on their own. There is no current US court doctrine for limiting free speech with regard to hate unless the content and situational details add up to something that fails the Brandenburg test.