Disorderly Conduct Juvenile Arizona

In In re Louise C., 197 Ariz. 84, 3 P.3d 1004 (App. 1999) Louise was prosecuted under the disorderly conduct statute for using "abusive or offensive language or gestures to any person in a manner likely to provoke immediate physical retaliation by such person." Id. at 86, P 6, 3 P.3d at 1006. Louise yelled at an assistant principal, "Fuck this. I don't have to take this shit. . . . Fuck you. I don't have to do what you tell me." Id. at 85, P 2, 3 P.3d at 1005. The Court reversed Louise's delinquency adjudication, finding that her language, though offensive, did not constitute fighting words because it was not directed at the principal, and "it was not likely to provoke an ordinary citizen to a violent reaction, and it was less likely to provoke such a response from a school official." Id. at 86, P 8, 3 P.3d 1006.