Which Statement About "Fighting Words" Is MOST Accurate

Which statement about "fighting words" is MOST accurate?

A) "Fighting words" have been considered protected speech throughout American history, and the Supreme Court has always reversed convictions based on arguments that the speaker used "fighting words."
B) Since the 1950s, the Supreme Court has been inconsistent in its rulings on "fighting words" cases and chosen to overturn convictions only when they involve "hate speech."
C) Since the 1950s, the Supreme Court has reversed almost every conviction based on arguments that the speaker used "fighting words."
D) Since the 1950s, the Supreme Court has never reversed a conviction based on arguments that the speaker used "fighting words."