Free Speech, Fleeting Expletives, and the Causation Quagmire: Was Justice Scalia Wrong in Fox Television Stations?

This Article concentrates on one particular issue raised in the Fox Television Stations ruling - the critical question of causation of harm caused by mass media messages and, in particular, the quantum of evidentiary proof needed by a federal agency to demonstrate causation sufficient to justify restricting the speech in question. The issue is ripe for review.