Id. at 420. The standard articulated in S.L.J. actually incorporates two distinct lines of United States Supreme Court case law. The S.L.J. opinion defines “fighting words” in terms of whether a mere utterance would “tend to incite an immediate breach of the peace.” Id. at 418 (quoting Lewis v. City of New Orleans, 415 U.S. 130,132, 94 S.Ct. 970, 972, 39 L.Ed.2d 214 (1974)). Other Supreme Court decisions, however, state that for an utterance to be considered fighting words, it must be an insult personally directed at an individual. See, e.g., Cantwell v. Connecticut, 310 U.S. 296, 309-10, 60 S.Ct. 900, 906, 84 L.Ed. 1213 (1940) (overturning fighting words conviction for lack of “personal abuse”); see also Gooding v. Wilson, 405 U.S. 518, 524, 92 S.Ct. 1103, 1107, 31 L.Ed.2d 408 (1972) (<HOLDING>). The separate issue of “intentionally
holding that theft from the person is not a crime of violence holding that fighting words must have a direct tendency to cause acts of violence by the person to whom individually the remark is addressed holding that a threat to harm another person is a crime of violence holding that the party against whom collateral estoppel is asserted must have been a party to the prior action holding with no analysis that any person or organization who may be legally liable therefor applies to a person legally liable for injuries caused by an accident   4 when under the facts of the case the only person to whom the clause could have applied was a tortfeasor