first amendment free speech protections. Third, the Court is wary of broad rules or categorical holdings framing the relationship between laws protecting individual privacy and the first amendment. See VanBuren, 2018 VT 95, ¶ 38. ¶ 66 Specifically, the nonconsensual dissemination of private sexual images causes unique and significant harm to victims in several respects. Initially, this crime can engender domestic violence. Perpetrators threaten disclosure to prevent victims from ending relationships, reporting abuse, or obtaining custody of children. Sex traffickers and pimps threaten disclosure to trap unwilling individuals in the sex trade. Rapists record their sexual assaults to humiliate victims and deter them from reporting the attacks. Schein, supra, at 1963; Franks, supra, at 1258; see Citron & Franks, supra, at 351. ¶ 67 Also, the victims’ private sexual images are disseminated with or in the context of identifying information. Victims are frequently harassed, solicited for sex, and even threatened with sexual assault (Schein, supra, at 1963-64; Franks, supra, at 1259; Citron & Franks, supra, at 353) and are fired from their jobs and lose future employment opportunities (Franks, supra, at 1259; Bustamante, supra, at 365-66; Citron & Franks, supra, at 352-53). Victims additionally suffer profound psychological harm. Victims often experience feelings of low self-esteem or worthlessness, anger, paranoia, depression, isolation, and thoughts of suicide. Schein, supra, at 1964; Bustamante, supra, at 366-67; see Citron & Franks, supra, at 350-51; Souza, supra, at 103 (“Beyond the obvious embarrassment suffered, victims are often threatened with bodily harm, fired from their jobs, or forced to change their names. Some have been driven to suicide.”). ¶ 68 Additionally, the nonconsensual dissemination of sexual images disproportionately affects women, who constitute 90% of the victims, while men are most commonly the perpetrators and consumers. Schein, supra, at 1961; Franks, supra, at 1259 (acknowledging that the crime affects both men and women, but stating that “available evidence to date indicates that the majority of victims are women and girls”). ¶ 69 In a brief time span, 43 states and the District of Columbia have enacted laws prohibiting the nonconsensual dissemination of private sexual images. These widespread efforts demonstrate that government recognizes the plight of victims of this crime and their need for protection. See Nisttáhuz, supra, at 357. “No one can - 20 -