Insulting E-Mail to Ex-Lawyer Wasn't Unprotected True Threat or Fighting Words

Michigan Court of Appeal Chief Judge Michael F. Gadola and Judges Thomas C. Cameron and Matthew S. Ackerman : E-mails to ex-lawyer were not protected under First Amendment .

Court of Appeals reversed, concluding that the speech didn't constitute an unprotected "true threat" of illegal conduct.

Court: Respondent's e-mails were offensive and inappropriate but did not express intent to commit an act of unlawful physical violence.

Court: Speech made over the Internet, "far removed from any potential violence," is not "inherently likely to provoke a violent reaction" Speech with expressive content, even if offensive, does not fall within narrow categories of historically unprotected speech.