Early in its history, the common law found it imperative to acknowledge and define an individual's interest in his personal integrity, physical safety and mental tranquility. The law formulated the legal rules of assault to protect this particular interest when it is wrongfully interfered with by another.' In this latter half of a nerve-wracking twentieth century, it is becoming necessary to revive the early concepts of common law assault, and under certain circumstances, to redress abusive and insulting language. Any principle of common law, particularly one concerned with the control of human behavior, has social implications, and such principle, whether dealing with a tort or a crime, must advance or retreat according to the social need. Outrageous behavior, encompassing overt antisocial acts and abusive language, is once again being recognized by the authorities to be a legal as well as a social problem
Ranelle A. Gamble,
Threats as Criminal Assault,
20 Clev. St. L. Rev.
available at https://engagedscholarship.csuohio.edu/clevstlrev/vol20/iss1/61