Not protected by who? Different courts have different interpretations. In fact, there are different definitions of harassment.
this territory is moderated
And there are already laws against harassment depending on the state or county
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"Hate speech" laws really started the terrible trend of legislatures and courts ignoring the 1st amendment. Maybe that will change with the new Supreme Court.
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For instance in Germany and England, anti immigration rhetoric is considered hate speech.
Of course there are more relevant examples here
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