Throughout the history of First Amendment jurisprudence, the Supreme Court has struggled with the question of how to treat speech that offends and insults an individual or group of people. Proponents of restrictions on such speech generally have relied upon three arguments. First, the speech often has little value and contributes nothing to the marketplace of ideas. Second, such speech amounts to a verbal assault that injures its target, even if not physically. And, finally, such speech may prompt the targeted group or individual to respond with violence of their own.