Mark Wooden sent an e- mail to an alderwoman for the city of St. Louis. Attached was a nineteen- minute audio file that compared her to the biblical character Jezebel. The audio said she was a “bitch in the Sixth Ward,” spending too much time with the rich and powerful and too little time with the poor. In a men-acing, maniacal tone, Wooden said that he was “ dusting off a sawed- off shotgun,” called himself a “ domestic terrorist,” and referred to the assassination of President John Kennedy, the murder of federal judge John Roll, and the shooting of Representative Gabrielle Giffords. Feeling threatened, the alderwoman called the police. Wooden was convicted of harassment under a state criminal statute. Was this conviction unconstitutional under the First Amendment? Discuss.