Right now I can't think of another way to distinguish generally hateful speech (which I may dislike but want to see protected) from verbal attacks, fighting words, bullying/harassment. An anti-abortion protester should have the right to hold up a sign with an aborted fetus and express the opinion "abortion is murder". But that same person should not be allowed to pick out a woman and scream "you are murdering your baby!" at that woman's face.