I think (based on seeing how many of these types of messages are coming up in discovery in recent cases) that many people these days don't think of "text messages" (email, SMS, WhatsApp, Slack, FB, you name it) qualify as "in writing". Doubtful most people would dare write a printed memo and sign their name to it with the same content that they would write in a text or email.

True, but when I said "in writing", I meant including various instant messaging and email.

I wasn't being specific with the word "clown", but every organization has employees critical of their manager. If you are a manager, you just have to accept that some people won't agree with your methods and will share their thoughts with others.

Yes, I understood.

What I mean is that I've never personally seen anyone engage in a personal attack toward a manager in written form, not the use of "clown" in particular.

I've seen plenty of criticism about various managerial practices, but that's entirely different from personal attacks.