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Keywords

lawsuittortliabilitymotion
tortliabilityverdictmotioncompliancepiracy

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Snyder v. Phelps, 562 U.S. 443, 131 S.Ct. 1207, 179 L.Ed.2d 172, 79 USLW 4135, 39 Media L. Rep. 1353, 11 Cal. Daily Op. Serv. 2774, 2011 Daily Journal D.A.R. 3307, 22 Fla. L. Weekly Fed. S 836

Facts

Fred Phelps and members of the Westboro Baptist Church picketed the funeral of Marine Lance Corporal Matthew Snyder, who was killed in Iraq. The church's signs, which included messages like 'Thank God for Dead Soldiers' and 'God Hates Fags,' were displayed on public land approximately 1,000 feet from the church where the funeral was held. Snyder, the deceased's father, saw the tops of the signs while driving to the funeral but did not learn the full content until later. He subsequently filed a lawsuit against the church for emotional distress and other claims.

Snyder filed a diversity action against Phelps, his daughters—who participated in the picketing—and the church (collectively Westboro) alleging, as relevant here, state tort claims of intentional infliction of emotional distress, intrusion upon seclusion, and civil conspiracy.

Issue

Whether the First Amendment protects the Westboro Baptist Church from tort liability for its picketing near the funeral of Matthew Snyder.

The question presented is whether the First Amendment shields the church members from tort liability for their speech in this case.

Rule

Speech on public issues is entitled to special protection under the First Amendment, and whether speech is of public or private concern is determined by examining its content, form, and context.

The Free Speech Clause of the First Amendment can serve as a defense in state tort suits, including suits for intentional infliction of emotional distress.

Analysis

The Supreme Court analyzed the content of Westboro's signs, concluding that they addressed public issues such as the political and moral conduct of the United States and its citizens. The Court noted that the context of the speech, being at a funeral, did not change its public nature. The church's peaceful demonstration complied with local law enforcement guidance, and the Court emphasized that the emotional distress caused by the speech was not sufficient to impose liability, as the speech was protected under the First Amendment.

The content of Westboro's signs plainly relates to public, rather than private, matters.

Conclusion

The Supreme Court held that the First Amendment shields Westboro from tort liability for its picketing, affirming the Fourth Circuit's decision and emphasizing the need to protect even hurtful speech on public issues.

The jury verdict imposing tort liability on Westboro for intentional infliction of emotional distress must be set aside.

Who won?

Westboro Baptist Church prevailed in the case because the Supreme Court found that their speech was protected under the First Amendment, which shields them from liability for emotional distress claims.

Westboro addressed matters of public import on public property, in a peaceful manner, in full compliance with the guidance of local officials.

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