Volokh finds “the use of criminal libel law in political disputes… troubling.” I’ll say. I mean, that was Walker’s point — government using its power to intimidate political opponents — and Chisholm’s instinct was to threaten to use government power to intimidate political opponents. Of course, that’s a despicable chilling of free speech. In fact, it’s chilly enough around here that, on proofread, I wondered whether I ought to be writing “threat” and “threaten.”