Connecticut v. Snyder
In Connecticut v. Snyder, 49 Conn. App. 617, 717 A.2d 240 (Conn. App. 1998), the state appealed from a dismissal prior to trial of charges that the defendant violated a statute that subjected one to criminal penalties when, "with intent to harass, annoy or alarm another person, he communicates with a person by telegraph or mail, by electronically transmitting a facsimile through connection with a telephone network, by computer network . . . or by any other form of written communication, in a manner likely to cause annoyance or alarm . . . ." Snyder, 717 A.2d at 245.
The Snyder court rejected the defendant's challenge that the statute was unconstitutionally overbroad, relying on principles similar to those set forth above in the Maryland decisions. See id. at 246.
It also quoted with approval an earlier Connecticut case explicating First Amendment principles in the context of telephone harassment:
Where the means of communication involves an intrusion upon privacy, the right of free expression must be balanced against the right to be let alone. . . . A telephone is not a public forum where, in vindication of our liberties, unreceptive listeners need be exposed to the onslaught of repugnant ideas. . . . The overbreadth principle is not violated by the unrestricted scope of the messages which the statute may ban because it is the manner and means employed to communicate them which is the subject of the prohibition rather than their content. . . . The prohibition is against purposeful harassment by means of a device readily susceptible to abuse as a constant trespasser upon our privacy. Id. at 243-44.