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The use of simple profanity directed at a person who is present, seems to me to be the essence of fighting words. A citizen who is not a public official, having such language repeatedly directed at them in this manner, would have a cause of action, why not a police officer? The use of the word Nazi is more of a fine line. Sure, used as an epithet, its a very nasty thing to call someone. But, it could be a valid political criticism too. There are organizations that espouse a Nazi ideology, and it would be viewpoint discrimination to enforce under color of law that "You can't call them Nazis."

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