The dancehall deejays of the 1980s and ’90s who refined the practice of “toasting” (rapping over instrumental tracks) were heirs to reggae’s politicization of music. These deejays influenced the emergence of hip-hop music in the United States and extended the market for reggae into the African American community. At the beginning of the 21st century, reggae remained one of the weapons of choice for the urban poor, whose “lyrical gun,” in the words of performer Shabba Ranks, earned them a measure of respectability.

Pete Rock – 914 bw The PJ’s (VLS) (2006) [Vinyl] [FLAC] [24-96]

What level of knowledge of rap and understanding of its complicated conventions is a defendant-speaker to assume, in advance of communication, that a hypothetically reasonable person possesses in order to properly understand a rap message? Because the answer is anything but clear and because a speaker’s First Amendment rights should not hang on what amounts to guesswork about an audience’s hypothetically reasonable knowledge of a complex artistic and political genre of expression, the actual subjective intent of the defendant-speaker must be considered in both the First Amendment and statutory true threats analyses.