ABSTRACT
Fear often results in pressure to curtail rights of free expression. The late Thomas Emerson provided four values inherent in the protection of free expression. It is government actors who are restricted by First Amendment, not individuals. Words are sometimes not speech but action, and actions can sometimes be considered protected free expression. The First Amendment attempts to protect both the rights of the speaker and the listener, but sometimes those rights may be in conflict. Rights of free expression are never absolute; there are multiple factors considered in determining the limits.
