Regrettably, the House Democrats have forgotten an important lesson from the impeachment trial of President Andrew Johnson. In 1868, the Radical Republicans impeached the Tennessee Democrat for using "intemperate" and "inflammatory" language that was critical of Congress. Ultimately, Johnson was never convicted on this charge, in part, because pivotal Republican Senators insisted that the First Amendment protects the President's freedom of speech. History may repeat itself again soon. To secure a conviction, House managers, acting as prosecutors, must make their case to the Senate, and to the country, that convicting Trump is consistent with the First Amendment. The President's right to free speech should not be simply dismissed out of hand.
What First Ammendment? The Democrats abolished that early last year when they banned lockdown protests, church attendance, and banned any news outlets or websites they didn’t like.
https://reason.com/volokh/2021/01/14/we-should-not-forget-the-free-speech-lessons-from-president-johnsons-impeachment-trial/