The First Amendment is a guarantee of free speech as it states that “Congress shall make no law . . . abridging freedom of speech, or of the press...”. This doesn’t apply only to the freedom of a person to verbally express themselves, but also, according to judicial review and interpretation, a person’s right to non-verbally express themselves. However, limitations to the extent one can exhibit their right to freedom of speech do exist. These limitations were stated by the Supreme Court in the ruling in the case Chaplinsky v. New Hampshire (1942) where it was determined that the use of fighting words, defamatory speech, and lewd and profane speech cannot be considered as freedom of speech.