Snyder v. Phelps
179 L. Ed. 2d 172 · Supreme Court of the United States · 2011
Facts
Members of the Westboro Baptist Church picketed Marine Lance Corporal Matthew Snyder's funeral on public land, displaying signs expressing anti-gay and anti-military sentiments. Snyder, the deceased's father, sued for intentional infliction of emotional distress, intrusion upon seclusion, and civil conspiracy, and a jury awarded him millions in damages. The Court of Appeals reversed, finding First Amendment protection for the speech.
Issue
Does the First Amendment protect members of the Westboro Baptist Church from tort liability for intentional infliction of emotional distress, intrusion upon seclusion, and civil conspiracy for picketing a military funeral with offensive signs on public land?
Holding
Yes, the First Amendment shields the Westboro Baptist Church members from tort liability for their speech. The Supreme Court affirmed the Court of Appeals' decision, finding the speech protected.
Rule
Speech on matters of public concern, conducted peacefully on public property, is entitled to "special protection" under the First Amendment, even if it is offensive or hurtful. The "outrageousness" standard for intentional infliction of emotional distress is too subjective to overcome this protection, and the captive audience doctrine does not apply when picketing is distant and non-disruptive.
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