Since when was fraud covered under the 1st Ammendment?

Professor's visit sparks furor at Eastern Washington University
By John K. Wiley The Associated Press
CHENEY, Spokane County — A Colorado professor whose formal visit was canceled because of safety concerns criticized administrators yesterday on the Eastern Washington University (EWU) campus, where he spoke after a compromise was reached.
Ward Churchill, whose remarks comparing some Sept. 11 victims to a Nazi war criminal touched off a firestorm and prompted calls for his firing, was a guest of EWU's Native American Student Association.
Scores of uniformed police officers stood by as Churchill told about 500 students gathered at the university's outdoor mall that his appearance was a victory for their free-speech rights.
Churchill earlier had gone to a federal court to try to force the university to rescind its cancellation of a planned speech. Instead, Churchill was allowed to lecture ethnic-studies classes and speak at the Native American Awareness Week rally.
"It was stated clearly, and in English, that the administration's posture here, in attempting to cancel [the formal speech] ... carried clear implications of unconstitutional prior restraint of speech," Churchill said.
"The job assignment of any academic institution ... is to see to it that the academic mission of the institution is fulfilled, not to prevent it, not to shape it to the purposes of their funders," he said, calling security concerns "bogus."
Churchill's remarks were received with polite applause, though a few boos could be heard.
EWU President Stephen Jordan in February canceled a scheduled speech by Churchill, a Colorado ethnic-studies professor, because of security concerns over Churchill's writings comparing some World Trade Center victims to Adolf Eichmann, an architect of the Nazis' "final solution" for European Jews during World War II.
http://archives.seattletimes.nwsource.com/cgi-bin/texis.cgi/web/vortex/display?slug=churchill06m&date=20050406&query=ward+churchill