Snyder v. Phelps

Snyder v. Phelps, 562 U.S. 443 (2011), is a landmark decision by the Supreme Court of the United States in which the Court held that speech made in a public place on a matter of public concern cannot be the basis of liability for a tort of emotional distress , even if the speech is viewed as offensive or outrageous.

On March 10, 2006, seven members of the Westboro Baptist Church (WBC), led by the church's founder Fred Phelps , picketed the funeral of U.S. Marine Matthew Snyder, who was killed in a non-combat accident during the Iraq War . On public land about 1,000 feet from where the funeral was being held, protesters displayed placards that read "Thank God for Dead Soldiers", "God Hates Fags ", and "You're Going to Hell", among others. Snyder's father, Albert Snyder, filed a lawsuit seeking damages from Phelps and the Westboro Baptist Church, claiming that their picketing was meant to intentionally inflict emotional distress . Phelps defended the picketing as an appropriate use of their right to free speech and right to peacefully protest as protected by the First Amendment to the U.S. Constitution .

The District Court of Maryland ruled in Snyder's favor and awarded him a total of $10.9 million in damages, but the Fourth Circuit Court of Appeals reversed, holding that the protesters' signs were "rhetorical hyperbole" and "figurative expression" and were therefore protected speech under the First Amendment. On further appeal, the U.S. Supreme Court also ruled in favor of Phelps, holding that speech made in a public place on a matter of public concern cannot be the basis for a claim of tort liability for intentional infliction of emotional distress. In an 8–1 decision delivered by Chief Justice John Roberts , the Court wrote that the First Amendment "shield[s] Westboro from tort liability for its picketing" because the speech was made on a matter of public concern and did not disrupt the funeral. The First Amendment provides special protection to public issues because it serves "the principle that debate on public issues should be uninhibited, robust, and wide-open."

Contents

• 1 Background

  • 1.1 Prior case law

  • 1.2 Facts of the case

  • 1.3 Lower court proceedings

• 2 Supreme Court

  • 2.1 Opinion of the Court

  • 2.2 Alito's dissent

• 3 See also

• 4 Footnotes

• 5 References

• 6 External links

Background

(https://en.wikipedia.org/w/index.php?title=Snyder_v._Phelps&action=edit&section=1 "Edit section: Background")

Prior case law

(https://en.wikipedia.org/w/index.php?title=Snyder_v._Phelps&action=edit&section=2 "Edit section: Prior case law")

The First Amendment to the United States Constitution protects the freedom of speech , even if the speech is considered hateful , unless the speech falls in one of several narrow exceptions to First Amendment protection that the Supreme Court has defined over time.

Facts of the case

(https://en.wikipedia.org/w/index.php?title=Snyder_v._Phelps&action=edit&section=3 "Edit section: Facts of the case")

The Westboro Baptist Church (WBC), often described as a hate group , was founded by Fred Phelps in 1955 and is headquartered in Topeka, Kansas . The congregation consists of about "sixty or seventy members", the majority of them being Phelps's children, grandchildren, relatives, and in-laws. Since Westboro's founding, members of the church have picketed hundreds of military funerals "to communicate its belief that God hates the United States for its tolerance of homosexuality, particularly in America's military".

On March 3, 2006, Matthew Snyder, a Lance Corporal of the United States Marine Corps , was killed in a non-combat-related vehicle accident in the Anbar Province of Iraq during the Iraq War . Shortly after in Snyder's hometown of Westminster, Maryland , his parents Albert and Julie Snyder, then divorced , were separately informed of his death by two Marines. Snyder's death was announced in local newspapers on March 7, and his funeral time and location was announced on March 8. The Westboro Baptist Church issued a press release on March 8 stating that they learned of Snyder's death and that members of the church, including Fred Phelps, planned to travel from Kansas to Maryland in order to picket Snyder's funeral, which was scheduled for March 10 at St. John's Catholic Church in Westminster.

Shortly before Snyder's funeral on March 10, picketers stood on public land about 1,000 feet from the church and displayed placards such as "Thank God for Dead Soldiers", "Thank God for IEDs", "God Hates Fags", "Fag Troops", "America is Doomed", "God Hates the USA/Thank God for 9/11", "Pope in Hell", "Priests Rape Boys", "Don't Pray for the USA", and "You're Going to Hell". The protest lasted about thirty minutes and ended before the funeral began. Following the funeral, Phelps's daughter Shirley Phelps-Roper published statements on the Westboro Baptist Church's website that denounced Albert and Julie Snyder for raising their son Catholic , stating that they "taught Matthew to defy his creator", "raised him for the devil", and "taught him that God was a liar".

WBC members picketing a military funeral in Yakima, Washington in 2005

Lower court proceedings

(https://en.wikipedia.org/w/index.php?title=Snyder_v._Phelps&action=edit&section=4 "Edit section: Lower court proceedings")

Albert Snyder brought a lawsuit against Fred Phelps and the Westboro Baptist Church in the District Court for the District of Maryland for defamation , intrusion upon seclusion , publicity given to private life , intentional infliction of emotional distress , and civil conspiracy . Snyder's claims of defamation and publicity given to private life were dismissed pursuant to Westboro's request for summary judgment and the case proceeded to trial on the remaining three counts.

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