"I know all about violence and physical abuse because my first husband used to beat me severely when he got drunk. Once, I can remember coming home from a party and walking up our vast marble staircase at the Fifth Avenue house while he was striking me. I thought, If I just gave him one shove down the staircase I would be rid of him forever."

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But it is recognized that punishment for the abuse of the liberty accorded to the press is essential to the protection of the public, and that the common law rules that subject the libeler to responsibility for the public offense, as well as for the private injury, are not abolished by the protection extended in our constitutions. The law of criminal libel rests upon that secure foundation. There is also the conceded authority of courts to punish for contempt when publications directly tend to prevent the proper discharge of judicial functions.

— Charles Evans Hughes