Touro Law Review Volume 29 Number 2 Article 13 October 2013 Speech as a Weapon: Planned Parenthood v. American Coalition of Life Activists and the Need for a Reasonable Listener Standard Alex J. Berkman Follow this and additional works at: https://digitalcommons.tourolaw.edu/lawreview Part of the Constitutional Law Commons, First Amendment Commons, Health Law and Policy Commons, Law and Gender Commons, Law and Society Commons, Medical Jurisprudence Commons, and the Privacy Law Commons Recommended Citation Berkman, Alex J. (2013) "Speech as a Weapon: Planned Parenthood v. American Coalition of Life Activists and the Need for a Reasonable Listener Standard," Touro Law Review: Vol. 29 : No. 2 , Article 13. Available at: https://digitalcommons.tourolaw.edu/lawreview/vol29/iss2/13 This Comment is brought to you for free and open access by Digital Commons @ Touro Law Center. It has been accepted for inclusion in Touro Law Review by an authorized editor of Digital Commons @ Touro Law Center. For more information, please contact
[email protected]. Speech as a Weapon: Planned Parenthood v. American Coalition of Life Activists and the Need for a Reasonable Listener Standard Cover Page Footnote 29-2 This comment is available in Touro Law Review: https://digitalcommons.tourolaw.edu/lawreview/vol29/iss2/13 Berkman: Speech as a Weapon SPEECH AS A WEAPON: PLANNED PARENTHOOD V. AMERICAN COALITION OF LIFE ACTIVISTS AND THE NEED FOR A REASONABLE LISTENER STANDARD Alex J. Berkman* ** I. INTRODUCTION On May 31, 2009, Dr. George Tiller was shot and killed at his church in Kansas.1 Prior to his death, Dr. Tiller, one of the nation‘s only late-term abortion providers, was regularly targeted by anti- abortion extremist groups.2 Along with other physicians, Dr.