"In this instance, for example, the speech involved in talk therapy is, for all practical purposes, analogous to electric-shock therapy. It is a method of therapy, and it is the method, not the speech as such, that is being regulated. This is a common phenomenon. The state can regulate bribery, threats, conspiracy, and many other forms of 'speech' because, in context, what is being regulated is not the speech as such, but the underlying course of conduct, of which the speech is but a part."
Says lawprof Geoffrey R. Stone, cautioning against a "too literal... understanding of the constitutional guarantee of 'the freedom of speech."