<P> The Supreme Court has held that "advocacy of the use of force" is unprotected when it is "directed to inciting or producing imminent lawless action" and is "likely to incite or produce such action". In Brandenburg v. Ohio (1969), the Supreme Court unanimously reversed the conviction of a Ku Klux Klan group for "advocating...violence...as a means of accomplishing political reform" because their statements at a rally did not express an immediate, or imminent intent to do violence . This rule amended a previous decision of the Court, in Schenck v. United States (1919), which simply decided that a "clear and present danger" could justify a congressional rule limiting speech . The primary distinction is that the latter test does not criminalize "mere advocacy". </P> <P> In 2017, a juvenile court in Massachusetts ruled that repeatedly encouraging someone to commit suicide was excluded from First Amendment protection, and found a 20 - year - old woman, who was 17 at the time, guilty of manslaughter on this basis . The judge cited a little - known 1816 precedent . The woman is expected to file an appeal . </P> <P> In Gertz v. Robert Welch, Inc. (1974), the Supreme Court decided that there is "no constitutional value in false statements of fact". However, this is not a concrete rule as the Court has struggled with how much of the "speech that matters" can be put at risk in order to punish a falsehood . </P> <P> The Supreme Court has established a complex framework in determining which types of false statements are unprotected . There are four such areas which the Court has been explicit about . First, false statements of fact that are said with a "sufficiently culpable mental state" can be subject to civil or criminal liability . Secondly, knowingly making a false statement of fact can almost always be punished . For example, libel and slander law are permitted under this category . Third, negligently false statements of fact may lead to civil liability in some instances . Additionally, some implicit statements of fact--those that may just have a "false factual connotation"--still could fall under this exception . </P>

What are two limitations to the first amendment freedoms