State v. Anonymous
Appellate Division of the Superior Court of Connecticut
389 A.2d 1270 (1978)
The defendant confronted the complainant in a parking lot, yelling insults and threats from her car window, and later called the complainant at work repeating the same insults; she was convicted of both disorderly conduct (for intentionally or recklessly interfering with another through offensive conduct causing 'inconvenience, annoyance, or alarm') and harassment (for a phone call intended to annoy or alarm), and appealed, arguing both statutes were unconstitutionally overbroad and that the jury should have been instructed it could convict only upon finding she used 'fighting words.'
Whether a conviction based on an overbroad statute that criminalizes constitutionally protected conduct will be invalid if jury instructions limiting the statute's reach are not given.