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33 T. Jefferson L. Rev. 273 (2010-2011)
Catcalls: Protected Speech or Fighting Words

handle is hein.journals/tjeflr33 and id is 277 raw text is: CATCALLS: PROTECTED SPEECH OR FIGHTING WORDS? INTRODUCTION With the recent technological advances in mobile phone applications, victims of catcalling and street harassment can instantly document their unwanted encounters.' In the past, catcalling and similar behavior in public places went undocumented unless the victim walked the streets with a camcorder in hand.2 Currently, websites like Holla Back DC!3 and Stop Street Harassment4 infom the public about incidents of unwanted catcalling and attention in public places, and give victims a forum to discuss their experiences.5 In most of these catcalling incidents, the First Amendment shields the catcaller's behavior; however, First Amendment protections are not limitless. The First Amendment does not protect 1. Karen Zraick, Phone Apps Aim to Fight Harassment, THE NEW YORK TIMES (Nov. 7, 2010), http://www.nytimes.com/2010/11/08/nyregion/08hollaback.html (explaining how using mobile applications to document these incidents may help authorities identify hot spots and catch offenders). 2. WAR ZONE (Film Fatale Inc. & Hank Levine Film 1998). In this documentary, Maggie Hadleigh-West walks the crowded New York City streets carrying a camcorder filming street harassment directed towards her and asks the men why they feel compelled to whistle or make comments to women who pass them on the street. In the process of documenting her encounters, she experiences gawking, leers and comments ranging from, Hey, beautiful! to Be a flicking bitch, all I said was hello. Strangers' reactions include pinching Hadleigh-West's breasts and slapping her buttocks. See also Deborah M. Thompson, The Woman in the Street: Reclaiming the Public Space From Sexual Harassment, 6 YALE J.L. & FEMINISM 313, 317 (1994) (citing Karen Avenoso, Capturing Harassment on Camera, TIMES- PICAYUNE, Sept. 8, 1993, at El; Lewd Remarks on the Street Lead Film Maker Into a War of Words, ARIZ. REPUBLIC, Dec. 21, 1993, at El.). 3. HOLLA BACK DC! (Mar. 25, 2011), http://hollabackdc.wordpress.com. Holla Back DC! allows victims of catcalling and street harassment a forum to share their experiences. Users post their pictures and stories of unwanted public harassment incidents while warning others which neighborhoods to avoid. 4. STOP STREET HARASSMENT (Mar. 25, 2011), http://www.stopstreet harassment.com. Stop Street Harassment takes an international approach to informing the public about street harassment. The site focuses on how men's harassment of girls and women limits gender equality and encourages people around the world to speak out and share their stories online. 5. Id. 6. U.S. CONST. amend. I. 273

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