Snyder v. Phelps

Snyder v. Phelps
Supreme Court of the United States
Argued October 6, 2010 Decided March 2, 2011
Full case name	Albert Snyder v. Fred W. Phelps Sr.; Westboro Baptist Church, Incorporated; Rebekah A. Phelps-Davis; Shirley L. Phelps-Roper
Docket no.	09-751
Citations	562 U.S. 443 (more) 131 S. Ct. 1207; 179 L. Ed. 2d 172; 2011 U.S. LEXIS 1903; 79 U.S.L.W. 4135; 39 Media L. Rep. 1353; 22 Fla. L. Weekly Fed. S 836
Argument	Oral argument
Opinion announcement	Opinion announcement
Case history
Prior	Judgment for the plaintiff, 533 F. Supp. 2d 567 (D. Md. 2008); reversed, 580 F.3d 206 (4th Cir. 2009); cert. granted, 559 U.S. 990 (2010).
Questions presented
Whether Hustler Magazine v. Falwell applies to a private person versus another private person concerning a private matter, and whether a funeral attendee is considered a "captive audience" entitled to state protection from unwanted communication.
Holding
Speech on a matter of public concern, in a public place, cannot be the basis of liability for a tort of emotional distress. Fourth Circuit affirmed, trial court reversed and remanded.
Court membership
Chief Justice John Roberts Associate Justices Antonin Scalia · Anthony Kennedy Clarence Thomas · Ruth Bader Ginsburg Stephen Breyer · Samuel Alito Sonia Sotomayor · Elena Kagan
Case opinions
Majority	Roberts, joined by Scalia, Kennedy, Thomas, Ginsburg, Breyer, Sotomayor, Kagan
Concurrence	Breyer
Dissent	Alito
Laws applied
U.S. Const. amend. I

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 appeal to the U.S. Supreme Court, the Court 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."^[1]