The first amendment does not apply to incidents in which speech causes "physical harm" and in which one side is blocking the free speech of the other side (like in the case of the protesters in UC Irvine against Michael Oren). By ramming a cart into the plaintiff, Zakharia blocked the plaintiff's free speech and caused her physical harm. Thus, he is not protected under the 1st amendment. about.
Kerry: Pollard's parole not related to Iran deal (Reuters)
from the article: Jewish student sues UC Berkeley over anti-Semitic attack