Over the part couple of months, I’ve been deluged by comment spam because somebody has listed SJ as a great place to get backlinks, and everyone with a computer in Bangalore has taken an interest.  These aren’t high quality spammers, but run of the mill spammers.

The content of the spam repeats itself, all based on the notion that by flattering the writer and the blog, the spam will see the light of day (glow of the monitor?).

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And of course, the age-old favorite:

Thank you for your interesting post. I have bookmarked it for future reading.

Point?  This is the sort of garbage, together with the dozens of variations on the theme, that seek to play on the blogger’s desire for validation and approval.  But we all know this, right?

Over at Concurring Opinions, regular Danielle Citron ventures where most thoughtful people would never go.  She takes on the First Amendment in support of Snyder against Phelps.

Herein lies a concern with the Court’s division of the speech universe between speech on public matters and those involving “purely“ private ones.  Some severely emotionally-damaging harassment of individuals stems from a perpetrator’s general hateful beliefs and involves victims who are strangers to the perpetrator.

Consider a neo-Nazi group’s online harassment of Bonnie Jouhari.  Posters on a white supremacist website targeted Ms. Jouhari, a civil rights advocate and mother of a biracial girl.  They revealed her home address and her child’s picture.  The site showed a picture of Ms. Jouhari’s workplace exploding in flames next to the threat that “race traitors” are “hung from the neck from the nearest tree or lamp post.”  Posters included bomb-making instructions and a picture of a hooded Klansman holding a noose. 

Ms. Jouhari suffered headaches and anxiety, and her daughter was diagnosed as suffering from severe post-traumatic stress disorder.  With the majority’s reasoning in hand, perpetrators of similar attacks might insist that intentional infliction of emotional distress claims should fail because they had long held discriminatory views, which can be understood as political objections to anti-discrimination laws, and had no previous contact with the individuals that they targeted.  They might contend that such attacks constituted protest on a matter of public concern, not a purely private matter deserving less First Amendment protection. 

I’ve taken the liberty of breaking up Citron’s writing into paragraphs. They are big now.  They were bigger before. 

She then lapsed into reliance on Justice Breyer’s concurrence.  Didn’t hear much about it?  There’s a reason.

[Justice Breyer] explains that the majority’s finding “does not hold or imply that the State is always powerless to provide private individuals with necessary protection.”  He find [sic] the decision quite narrow, explaining that its finding hinged on the fact that the Snyders could not see or hear the picketing from the funeral ceremony.  In Breyer’s view, “To uphold the application of state law in these circumstances would punish Westboro for seeking to communicate its views on matters of public concern without proportionately advancing the State’s interest in protecting its citizens against severe emotional harm.”

Considering that there were 8 in the majority, Citron’s search for comfort in the concurrence seems a bit off the wall.  But it’s not, given that her belief is that the harm of hate speech trumps the First Amendment.  My guess is somebody said something really mean to her during her formative years, and she’s never gotten over it.

And then there is a comment to Citron’s post.

Kenneth parkar – March 7, 2011 at 12:22 am

Hello,
I am Kenneth parkar and I am a member of some financial communities. I just visited your site (http://www.concurringopinions.com) and trust me you are doing a good job for your site. I read some of the articles of your site and I really found them worth reading. The quality of your content is excellent. It will help you to earn extra value from search engines.
After seeing this, I would like to do something for your site and that is for FREE!!. I love to write financial articles and I would like to contribute something for your site if you’ll give me the permission. I can give you an original guest post and I assure you that it will be published only in your site.
Please let me know your thoughts. Waiting for your positive reply. Reach me at:
kenneth.xxx @ gmail.com
Thanks and Regards
Kenneth parkar

[Note: I have some financial sites with Good PR, I can also give you back link from there]

This gives rise to two critical points: The First Amendment remains safe from Danielle Citron, and to all you spammers who I block and delete daily, they would love your thoughts over at Concurring Opinions, where any validating comment is appreciated.  Go tell Danielle Citron how much you enjoy and appreciate her thoughts.  She could use some love speech right about now, after the Supreme upheld the vitality of the First Amendment despite her efforts.  Just give her some validation and you can have as many backlinks as you want.

And leave me alone.