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Allegedly Calling Ex "Fat Fuck Iranian" Stemmed from "Desire to Be Left Alone," not "Anti-Iranian Sentiment"
Eugene Volokh | 1.9.2026 8:01 AM
From the First Circuit's decision Tuesday in Radfar v. Covino, written by Judge Seth Aframe, joined by Judges Kermit Lipez and Jeffrey Howard:
We present [the] facts in the light most favorable to Radfar…. In June 2015, Radfar, a George Mason University ("GMU") police officer, met Covino, a sergeant with the Revere Police Department, at a police event in Virginia. At that time, Covino and Radfar began a romantic relationship. After Covino returned to Massachusetts, he stayed in contact with Radfar.
Radfar visited Covino in the Boston area in August 2015, but during the visit, Covino said that he wanted to end the relationship. The two reconciled, and Radfar visited again two months later. Covino again told Radfar that he wanted to discontinue the relationship. Nevertheless, their communications continued. Radfar testified that in one phone call, Covino called her a "fat fuck Iranian" and stated that he hoped she would be "shot in [her] face with [her] service weapon."
In July 2016, Radfar returned by car to the Boston area. On that trip, she went uninvited to the Revere Police Department, Covino's place of employment, although he was not there at the time.
In January 2017, Radfar called Covino hundreds of times from over one hundred different phone numbers and sent him pictures of her that had been spliced with pictures of him. During that month, Covino called the GMU Public Safety Office and spoke to Lieutenant David Ganley. Covino informed Ganley about Radfar's conduct and said that he wanted a "clean break" from her. Ganley told Covino that Radfar's behavior was consistent with her past relationships. Covino stated that his "only concern [in contacting GMU] was having [Radfar] stay away from [him]."
Lieutenant Ganley reported Covino's phone call to interim GMU Police Chief Carl Rowan, Jr. Rowan, in turn, requested a meeting with the Virginia State Police ("VSP") to ask for an investigation into Radfar's actions. Rowan later testified that Covino........
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