Snyder v. Phelps

Following is the case brief for Snyder v. Phelps, 562 U.S. 443 (2011).

Case Summary of Snyder v. Phelps:

  • A church leader and several church members traveled to Maryland to picket at a military funeral.  The picketers held signs decrying the moral decline of the U.S. and homosexuality in the military.
  • The soldier’s father sued the church and church members because the picketing caused him emotional injury.
  • Although a jury awarded the father $5 million following a trial, the Court of Appeals reversed the award on First Amendment grounds.
  • The U.S. Supreme Court affirmed the Court of Appeals decision.  It held that the picketers’ speech was protected by the First Amendment because the speech involved issues of broad public concern.  Accordingly, the First Amendment shielded the picketers from tort liability.

Snyder v. Phelps Case Brief

Statement of the Facts:

Marine Lance Corporal Matthew Snyder was killed in the line of duty while serving in Iraq.  His father planned a funeral ceremony for him in their hometown in Maryland.  On the day of the service, Fred Phelps and members of his Westboro Baptist Church picketed close to where the service was held. Phelps and his church members carried signs with slogans such as “Thank God for Dead Soldiers,” “Priests Rape Boys,” and “God Hates Fags.”

The picketers complied with all police instructions in staging their demonstration, they did not yell or use profanity, and they displayed their signs for 30 minutes after which they sang hymns and recited Bible verses.  The funeral procession came approximately 200-300 feet away from the picketers. Snyder’s father could see the tops of signs, but could not see what they said.  He only learned about what the signs said after seeing TV news reports later that evening. Snyder’s father stated that he often becomes tearful, angry, and physically ill when he thinks about the picketing at his son’s funeral.

Procedural History:

Snyder’s father filed suit in Federal District Court against Phelps, the church, and others.  He alleged the tort claims of defamation, publicity given to private life, intentional infliction of emotional distress, intrusion upon seclusion, and civil conspiracy.  The District Court dismissed the first two claims.  After a trial, the jury awarded Snyder $5 million on the final three claims.  The Fourth Circuit Court of Appeals reversed the jury verdict and award on First Amendment grounds.  The U.S. Supreme Court granted certiorari.

Issue and Holding:

Does the First Amendment protect people from tort liability when they picket a military funeral?  Yes.

Judgment:

The Fourth Circuit Court of Appeals ruling is affirmed.

Rule of Law or Legal Principle Applied:

The First Amendment protects speech that is made in public places on matters of public concern, regardless of how outrageous that speech may be.

Reasoning:

The First Amendment provides special protection to speech on public issues.  A court must look to the content, form, and context of the speech to determine whether it is of public or private concern. In this case, the content of the picketers’ speech was related to broad public issues, such as the moral conduct of the U.S. and homosexuality in the military.  While the context of the speech occurred at Snyder’s funeral, it cannot be concluded that the speech was a personal attack on Matthew Snyder.

In sum, the picketers addressed broad public issues, on public property, in a peaceful manner, without disrupting the funeral service.  Accordingly, the First Amendment protects the picketers from tort liability for their speech so that such discussion, even if hurtful or outrageous, is not stifled from public debate.

Concurring/Dissenting Opinions:

Concurring Opinion (Breyer):

The Court’s opinion is limited only to the Westboro Baptist Church’s picketing.  It did not apply to the TV coverage of the picketing, or the church’s internet postings.  Additionally, there are factual circumstances in which individuals are not powerless against harmful speech.

Dissenting Opinion (Alito):

The Westboro Baptist Church should not have been given protection of the First Amendment.  The church launched a cruel verbal attack on the Snyder family and caused lasting emotional injury.  The speech was aimed at Matthew Snyder.  Because broader public issues were also discussed does not mean that the Snyder family should be without a remedy.

Significance:

Snyder v. Phelps clarifies the Court’s view that the First Amendment protects even the most egregious speech provided that the speech is of public concern in a public space.

Student Resources:

https://www.supremecourt.gov/opinions/10pdf/09-751.pdf

https://www.oyez.org/cases/2010/09-751

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