In R.A.V. v. City of St. Paul, Minn. (1992) 505 U.S. 377, the Supreme Court reviewed the constitutionality of an ordinance that banned the display of a burning cross. The ordinance states: "'Whoever places on public or private property a symbol, object, appellation, characterization or graffiti, including, but not limited to, a burning cross or Nazi swastika, which one knows or has reasonable grounds to know arouses anger, alarm or resentment in others on the basis of race, color, creed, religion or gender commits disorderly conduct and shall be guilty of a misdemeanor.'" (R.A.V. v. City of St. Paul, Minn., supra, 505 U.S. at p. 380.) The high court found that the content-based ordinance was constitutionally defective because it punished the use of only those fighting words that insulted or provoked violence on the basis of disfavored categories: race, color, creed, religion or gender. Fighting words based on other categories were not included within the statute. ( Id. at p. 391.)