Mark Wooden sent e-mail to an alderwoman for the city of St. Louis. Attached was a nineteen-minute audio. In a menacing, 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 Congresswoman 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.

What speech or expression do you think Wooden made that was protected under the first amendment?