to punish her for exercising her free speech rights.’ ” (quoting Rutan v. Republican Party of Ill., 868 F.2d 943, 954 n. 4 (7th Cir.1989) (citing Bart, 677 F.2d at 622))). And it has been adopted or reaffirmed by a majority of our sister circuits. See, e.g., Welch v. Ciampa, 542 F.3d 927, 937 (1st Cir.2008) (recognizing retaliatory harassment may be actionable under objective test); Coszalter v. City of Salem, 320 F.3d 968, 976 (9th Cir.2003) (same); Naucke v. City of Park Hills, 284 F.3d 923, 928 (8th Cir.2002) (same); Toolasprashad v. Bureau of Prisons, 286 F.3d 576, 584-85 (D.C.Cir.2002) (same); Bloch v. Ribar, 156 F.3d 673, 679-80 (6th Cir.1998) (same); Bernheim v. Litt, 79 F.3d 318, 325-26 (2d Cir.1996) (same). But see McLaughlin v. Watson, 271 F.3d 566, 573-74 (3d Cir.2001) (<HOLDING>); Colson v. Grohman, 174 F.3d 498, 513-14 (5th
holding that the crime of knowingly and willfully threatening the president required only that the threat be made under circumstances where a reasonable person would foresee that the statement would be interpreted by those to whom it is addressed as a serious threat and not be the result of mistake duress or coercion holding that what is a threat must be distinguished from what is constitutionally protected speech holding that speech must be a threat or coercion to be actionable holding that in the first amendment employment context harassing speech must constitute constructive adverse employment action to be actionable holding that to be actionable the words must be communicated or published to someone other than the plaintiff