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This picture was tweeted by the comedian Kathy Griffin on May 3 0 , 2 0 1 7 , in what she later said was

This picture was tweeted by the comedian Kathy Griffin on May 30,2017, in what she later said was an attempt to draw attention to what she considered to be President Trumps sexist behavior. Mr. Trump, who was surely one of our most litigious presidents, did not sue Ms. Griffin. But suppose he had. In particular, suppose President Trump sued Ms. Griffin in civil court for intentional infliction of emotional distress, claiming that the photograph was so outrageous and beyond any bounds of decency in a civilized society that it caused him and his family severe anguish and torment that went far beyond mere annoyance, discomfort, or unease. Suppose Mr. Trump sought ten million dollars in damages for the injury he alleged that he and his family suffered. Suppose you were the attorney for Ms. Griffin. You claim that Ms. Griffins tweet was fully and completely protected by the First Amendment, and you move for summary judgment in favor of your client. In making your motion, on which of the following cases would you most rely?

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