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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
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.


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