planned parenthood v american coalition of life activists decision
American Coalition of Life Activists Planned Parenthood successfully sued the ACLA. Although the posters and website did not contain any specific threat, the jury awarded $107 million. The ACLA appealed the verdict on First Amendment grounds. A panel of the 9th Circuit Court of Appeals initially overturned the verdict, holding that the activities of the ACLA were protected under the First Amendment because they did not directly threaten harm to the plaintiffs, and because the ACLA's statements were not communicated privately to the plaintiffs. The en banc 9th Circuit reversed the panel<http://news.findlaw.com/hdocs/docs/abortion/ppacla51602opn.pdf>, and held that the ACLA could be held liable in damages because the website made a deliberate threat with the expectation that someone would act on it, unprotected by the First Amendment.