Obscene or Indecent Telephone Calls May Be Prohibited - Indecent telephone calls as well as obscene telephone calls may be prohibited.

Public Place Obscenities - At common law, use of obscene or indecent language in a public place was proscribable. Cohen v. California, raises doubt as to whether language which is not obscene in the Miller sense can be proscribed in public simply because it is "offensive" or indecent without amounting to "fighting words" or associated with conduct provoking a breach of the peace. "Fighting words" are usually properly punishable as breaches of the peace or disorderly conduct. Harassment statutes have been upheld.

Time, Place and Manner Restrictions - As with other forms of normally protected speech, non-obscene "obscene" language may be prohibited where it invades the privacy of the home or where other compelling state interests permit regulation of the same.

High School Student Speech - In the 1986 case of Fraser v. Bethel School District, the United States Supreme Court laid down the principle that students in a school environment do not have the same First Amendment rights as students or adults outside that environment. In that case, the Court agreed that school officials might punish students for lewd or vulgar speech if it materially disrupts class work, involves substantial disorder or invades the rights of others. In 1988, the restriction on student speech was expanded by the Supreme Court to clarify the control of school officials over the content of school sponsored student newspapers in the case of Kuhlmeier v. Hazelwood School District.