The court has continued to uphold the doctrine but also steadily narrowed the grounds on which fighting words are held to apply. In "Street v. New York" (1969), the court overturned a statute prohibiting flag-burning and verbally abusing the flag, holding that mere "offensiveness" does not qualify as "fighting words". In similar manner, in "Cohen v. California" (1971), Cohen's wearing a jacket that said "fuck the draft" did not constitute uttering fighting words since there had been no "personally abusive epithets".