In City of Houston, Texas v. Hill, 482 U.S. 451 (1987), the court stated that a significant amount of verbal criticism directed at a police officer is protected under the First Amendment. The court noted: "The freedom of individuals verbally to oppose or challenge police action without thereby risking arrest is one of the principal characteristics by which we distinguish a free nation from a police state." Id. 463. The Hill court struck the Houston ordinance in question because it "criminalizes a substantial amount of constitutionally protected speech and accords the police unconstitutional discretion in enforcement." Id. 466.