The Fourth Circuit ruled that the lower court had erred by instructing the jury to decide a question of law rather than fact (specifically, whether or not the speech in question was protected by the First Amendment).
第四巡迴法院裁定，下級法院錯誤指示陪審團決定法律問題，而非事實問題（特別是該言論是否應受第一修正案保護）。