Immigration authorities are being told "incitement" and "fighting words" are not protected by the First Amendment:

[stopdiggin]

8. the link probably does a better job, but ...

No. Each capitalization is a category of unprotected speech unto itself. They do not need interaction or compounding.

Generally - extorting 'protection' from your neighbor under threat to burn his house down - or phoning in ransom demand in a kidnapping - or issuing instruction rob a bank, or kneecap an informant .... All issue from criminal intent , regardless of whether the action is ever actually carried out.

Speech Integral to Criminal Conduct
In Giboney v. Empire Storage & Ice Co. (1949), the Supreme Court held the First Amendment affords no protection to “speech or writing used as an integral part of conduct in violation of a valid criminal statute.” A robber’s demand at gunpoint that you hand over your money is not protected speech. Nor is extortion, criminal conspiracy, or solicitation to commit a specific crime. Abstract advocacy of lawbreaking remains protected speech.

https://www.thefire.org/research-learn/unprotected-speech-synopsis