Haughwout v. Tordenti

**561 In this appeal, we consider the limits of free speech on a public university campus in light of recent history that has led federal and state courts to describe threats of gun violence and mass shootings as the twenty-first century equivalent to the shout of fire in a crowded theater once envisioned by Justice Oliver Wendell Holmes, Jr. See, e.g., Ponce v. Socorro Independent School District , 508 F.3d 765 , 772 (5th Cir. 2007) ; Milo v. New York , 59 F. Supp. 3d 513 , 517 (E.D.N.Y. 2014) ; In re A.S. , 243 Wis. 2d 173 , 194, 626 N.W.2d 712 (2001). The plaintiff, Austin Haughwout,…