Folks, there was a 1940’s case – Chaplinsky v. New Hampshire where the SCOTUS ruled that certain speech under certain conditions can be considered "fighting words," and that the person engaging in such speech can be punished if their utterances inflict injury or tend to incite an immediate breach of the peace.
If that doesn’t apply here, I don’t know what does. Now, be advised that in the interim, the courts haven’t favored the “fighting words’ doctrine but maybe as SCOTUS takes on a slightly different character and make-up, this might resurrect it. Maybe a test case is in order.