Post-Chaplinsky
The Court has continued to uphold the doctrine but also steadily narrowed the grounds on which fighting words are held to apply.
Not a lawyer, but the subsequent cases seem to limit the doctrine so much that it hasn't really been upheld at all. Basically now you can't be charged with assault if both parties literally agree to fight. Everything else sure seems to be covered as free speech.



I wonder if they could have been inspired by the writings (and some illustrations) of HP Lovecraft? I'm no lore expert there, but a Beholder wouldn't be out of place by the side of some of the others.