Snyder v. Phelps

131 S.Ct. 1207 (2011)

Purchase the Printed Copy at bsmsphd.com

Nature of the Case

To access this section all you need to do is click here and register.

Facts

Phelps (D) founded the Westboro Baptist Church. The church believes that God hates and punishes the United States for its tolerance of homosexuality, particularly in America’s military. The church pickets often at military funerals. They have picketed nearly 600 funerals. Lance Corporal Snyder was killed in Iraq in the line of duty. Snyder’s father (P) selected the Catholic church in Westminster, Maryland, as the site for his son’s funeral. D traveled to Maryland with six other parishioners to picket. They picketed on public land adjacent to public streets. Signs stated: “God Hates the USA/Thank God for 9/11,” “America is Doomed,” “Don’t Pray for the USA,” “Thank God for IEDs,” “Thank God for Dead Soldiers,” “Pope in Hell,” “Priests Rape Boys,” “God Hates Fags,” “You’re Going to Hell,” and “God Hates You.” D notified the authorities and complied with police instructions in staging their demonstration. The location was approximately 1,000 feet from the church where the funeral was held. Several buildings separated the picket site from the church. They displayed their signs for about 30 minutes before the funeral began and sang hymns and recited Bible verses. None of the picketers entered church property or went to the cemetery. They did not yell or use profanity, and there was no violence associated with the picketing. P did not see what was written on the signs until later that night while watching a news broadcast. P sued for defamation, publicity given to private life, intentional infliction of emotional distress, intrusion upon seclusion, and civil conspiracy. D moved for summary judgment contending, in part, that the church’s speech was insulated from liability by the First Amendment. D got summary judgment on defamation and publicity given to private life, concluding that P could not prove the necessary elements of those torts. A jury found for P on the intentional infliction of emotional distress, intrusion upon seclusion, and civil conspiracy claims, and held D liable for $2.9 million in compensatory damages and $8 million in punitive damages. The District Court remitted the punitive damages award to $2.1 million but left the jury verdict otherwise intact. The Court of Appeals concluded that D’s statements were entitled to First Amendment protection because those statements were on matters of public concern, were not provably false, and were expressed solely through hyperbolic rhetoric. The Supreme Court granted certiorari.