Law School Case Brief
Snyder v. Phelps - 580 F.3d 206
The United States Supreme Court has recognized that there are constitutional limits on the type of speech to which state tort liability may attach. Certain types of speech are protected regardless of the plaintiff's status as private or public figure. Thus, although there is no categorical constitutional defense for statements of opinion, the First Amendment will fully protect statements that cannot reasonably be interpreted as stating actual facts about an individual.
Marine Lance Corporal Matthew A. Snyder was killed in Iraq in the line of duty. Shortly thereafter, two United States Marines came to the home of Albert Snyder and told him that his son had died. As Matthew Snyder had lived in Westminster, Maryland, and graduated from Westminster High School, St. John's Catholic Church in Westminster was selected as the site for his funeral.
Defendant Fred W. Phelps, Sr., founded Defendant Westboro Baptist Church, Inc. in Topeka, Kansas. Among their religious beliefs is that God hates homosexuality and hates and punishes America for its tolerance of homosexuality, particularly in the United States military. Members of the church have increasingly picketed funerals to assert these beliefs. Defendants also established a website in order to publicize their religious viewpoint. One of the funerals they picketed at was Matthew Snyder's funeral. None of the defendants ever met any members of the Snyder family.
Albert Snyder, father of Matthew, instituted this diversity action in the District of Maryland against Westboro Baptist Church, Incorporated (the "Church"), and several of its members. Snyder complained invasion of privacy by intrusion upon seclusion, intentional infliction of emotional distress ("IIED"), and civil conspiracy. After the trial, the jury found the defendants liable for damages. Defendants have appealed, contending that the judgment contravenes the First Amendment of the Constitution.
Did the judgment against Phelps contravene the right to free speech?
The court reversed the judgment of the district court, holding that although Phelps’ picket signs, which conveyed messages such as "America is Doomed," "Fag Troops," and "Thank God for Dead Soldiers," were utterly distasteful, they involved matters of public concern, including the issue of homosexuals in the military and the moral conduct of the U.S. and its citizens. No reasonable reader could interpret any of these signs as asserting actual and objectively verifiable facts about the father or his son. Also, the statements were protected because they asserted non-provable facts and clearly contained imaginative and hyperbolic rhetoric intended to spark debate about issues that concerned Phelps and other members of the defendant church. Finally, the "epic" that Phelps posted about the family on the church's website, which was aimed at Catholics, was also protected because it was patterned after the hyperbolic and figurative language used on the picket signs.
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