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Roy S. Gutterman

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Westboro Ruling: The Bad and the Uglier for the Greater Good

Posted: 03/03/11 04:08 PM ET

When it comes to public issues, sometimes we need to accept a little bit of the ugly for the greater good. The Supreme Court solidly affirmed this with regard to free speech on Wednesday when it ruled that the Westboro Baptist Church's offensive protests outside the funeral of a fallen Marine is a form of protected speech.

Certainly, the church's message that the decline of American morals is the cause of death, despair and disasters is not a message many Americans can stomach. Chief Justice John Roberts acknowledged that the small church's message may be "morally flawed," but it is protected speech nonetheless.

Writing for the 8 to 1 majority in Snyder v. Phelps, the Chief Justice also acknowledged that speech in a public place about public issues not only deserves but demands First Amendment protection.

Providing a forum for these types of messages on public issues is central to the purpose of the First Amendment. There were times in our history when speech and protests on such causes as civil rights, women's rights, equality and peace were considered unpopular and in need of protection. (This is, of course, not to equate the Westboro Church's message with those vaunted causes.)

The complicated legal dispute in this case emanated from a private civil lawsuit filed by Albert Snyder, after a small group of church members staged a hateful protests outside the funeral of his son, Lance Corporal Matthew Snyder, who was killed in duty in Iraq. The protest was followed by a posting on the church's website.

Mr. Snyder brought a civil action based on an array of state tort laws, and won damages totaling $10.9 million. The key question before the court was whether the tort of intentional infliction of emotional distress (IIED) was viable under the circumstances. Could a civil action be used to recover damages for offensive and disturbing speech?

This was not the first time the Supreme Court looked at IIED through the lens of the First Amendment. In 1988, the Supreme Court found the tort unavailable to the Rev. Jerry Falwell, the well-known televangelist and leader of the Moral Majority, who was seeking damages against Hustler magazine for publishing an offensive ad parody about him. Ultimately, Falwell's case failed under the First Amendment because of his status as a public figure and the satirical content of the offensive copy which had significant political and social content.

In determining whether Mr. Snyder had a viable claim, the court not only looked at the elements of the cause of action -- intentional or reckless extreme and outrageous conduct that causes severe emotional distress -- but also the content and context of that offensive speech, which puts it in the realm of matters of public concern.

"While these messages may fall short of refined social or political commentary, the issues they highlight -- the political and moral conduct of the United States and its citizens, the fate of our Nation, homosexuality in the military, and scandals involving the Catholic clergy -- are matters of public import," Chief Justice Roberts wrote.

It is a shame that opportunistic crackpots are seizing upon tragedies and the pain suffered of the families of heroes and victims of unrelated events. The lone dissenter, Justice Samuel Alito, refused to accept the church's message as anything more than brutal attack on a private family. This message added nothing to the marketplace of ideas and was not worthy of protection, Justice Alito wrote.

But for every Westboro Church protest, there is a debate on legitimate public policy or government abuse that also demands protection.

The role of public debate is alive all around us, whether in a heated march on organized labor in the Midwest; or anti-tax and spending movements leading up to elections; or mass demonstrations leading to political change in the Middle East.

Here, the First Amendment exists to not only allow but to foster and protect debate -- even caustic, hostile, hurtful and "morally flawed" debate.

Roy S. Gutterman is an associate professor of communications law and journalism and director of the Tully Center for Free Speech at the S.I. Newhouse School of Public Communications at Syracuse University

 
 
 
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06:11 PM on 03/04/2011
Here's what I don't understand:

Why is this a free speech issue at all and why did the Supreme Court get involved? The only question, as far as I'm concerned, is whether the Westboro Baptist Church caused Snyder emotional damage. Sure, they have the right to say whatever they want to and no matter what this decision was, that doesn't change.

The reality is, though, that a jury of peers found that the intentional inflection of emotional damage occurred, and awarded Snyder damages. The Supreme Court then overturned that decision for free-speech grounds? Why?

In America, anyone can be sued for anything. Some woman is suing P. Diddy for bombing the World Trade Center. It's a frivolous lawsuit. But whether a lawsuit is frivolous is to be decided by the judge and by a jury. Westboro practiced their free speech rights in accordance with the law, and Snyder, also in accordance with the law, took offense to that practice and sued. It happens literally every day in America and this is no different.

It's not a free speech issue.
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dsws
No owning ideas. Limit only commercial use.
01:58 PM on 03/04/2011
"(This is, of course, not to equate the Westboro Church's message with those vaunted causes.) "

That word -- I do not think it means what you think it means. It's from the same root as "vanity": Latin vanare "to utter empty words".
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TXfemmom
Grandma with eye on the future
11:08 AM on 03/04/2011
Okay, Westbury has the right to spew this stuff...however, they should not be doing it with tax-exempt money.  Tax all churches and institutions connected with them except for what they can prove is used to feed or house the poor, elderly, or sick, food banks, and truly charitable things. 
 
The donations by individuals are not taxed, but the government and other people should not have to support promotion of any religion or the thoughts of what is referred to as a religion with tax-exempt money.  They have a right to free speech, but not on the public's dollar. 
 
We could probably balance the budget if churches and all their contrivances were subject to property taxes, school taxes, and income taxes.  That, along with the Constitutional vision of no support for a religion by the state should require that the tax-exempt status be removed. 
 
 
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10:29 AM on 03/04/2011
The question Americans must face: is hate speech targeted to a specific minority or identifiable populations to be equated the full protection of law as free speech? Subsequently, would we tolerate Hitler scapegoating Jews for societel ills or a Muslim Westboro? This is the extent we value our freedom.
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Jerry Bourbon
11:22 AM on 03/04/2011
Yes and Yes. Freedom of speech for ALL, idiots included.
12:52 PM on 03/04/2011
I am sceptical that we would protect a "Muslim Westboro". Talk about hate speech, imagine what would be said about (and done to) a group of Muslims attending a military funeral with Westoboro-esque signs. It would be ugly...
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myth buster
06:38 PM on 03/06/2011
Perhaps, but it would not be the government doing it.
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Jack Straw
10:12 AM on 03/04/2011
If they can make the protestors at the RNC move so far away from the convention hall that no one attending actually sees them protest, you would think someone who just lost a child could be afforded the same courtesy!
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TXfemmom
Grandma with eye on the future
11:09 AM on 03/04/2011
I agree.  They kept protestors away from the Republican convention by something like twenty blocks, but these people can get in the face of the bereaved?
nothingchanges
too soon old, too late smart
09:25 AM on 03/04/2011
There is something wrong with our moral values.
When seeing a woman's breast is considered obscene, and this is not.
08:19 AM on 03/04/2011
(Other) civilized countries have laws against hate speech.
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Jerry Bourbon
11:16 AM on 03/04/2011
So move to one. We like free speech in our country.
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nkurland
I'm going to leave this planet alive
02:19 PM on 03/04/2011
These are also laws that were enacted after the Holocaust...
07:09 AM on 03/04/2011
I live in Topeka and get to see them all the time. Over the years we have developed a way of dealing with them. They protest at various events and people have raffles to guess how long they will stay before leaving with all funds going to not for profits. I am sorry to say that our having effectively dealt with them may have thrust them onto the larger stage in their desperation for attention as the complete disdain they receive at home is humiliating for them I'm sure. My favorite story is from someone I know, really. They were protesting on the median in January in front of a church on the grass strip between the sidewalk and the street. She went out and yelled at them to get off her lawn. Her husband came out trying to get her back in. The policeman monitoring the situation said unfortunately the median is technically public property. She fumed and said but we have to take care of it and then the light bulb went off and she asked if it would be OK for her to water her lawn. The policeman thought for a moment and said he didn't see anything wrong with it and so she told her husband to get the sprinkler and they watered the lawn in January and the Phelps left yelling all the time. WE get creative in Topeka. Oh, her husband does shake his head a lot about her.
09:38 PM on 03/04/2011
Lovely story. Sorry you have to live in the same town with those people. But I'm curious . . . . how does the town respond to them? Do they have any friends, or are they mostly on their own, since the church's members are mostly family members? I would love to hear that no one in Topeka speaks to them. And it's too bad that they can't be refused service at restaurants, stores, supermarkets, etc. I do hope that entry is refused when they all reach the Pearly Gates.
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WorldEdition
Speak Truth to Power
04:17 AM on 03/04/2011
Local government can still restrict protest on public land a certain distance from a funeral, correct?

I heard this just said that the harmed person couldn't sue the protestor for emotional distress. That makes sense because the supreme court hates lawsuits filed by people
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catcancook
Obama/Biden 2012
10:34 AM on 03/04/2011
The Supreme Court restricts free speech in schools for certain things. But hurling insults at the dead and their families are protected.

However, since 1969 the Supreme Court has placed a number of limitations on Tinker interpretations. In Bethel School District v. Fraser, 478 U.S. 675 (1986), the Court ruled that a student could be punished for his sexual-innuendo-laced speech before a school assembly and, in Hazelwood v. Kuhlmeier, 484 U.S. 260 (1988), the Court found that school newspapers enjoyed fewer First Amendment protections and are subject to school censorship.

More recently, in Morse v. Frederick, 551 U.S. 393 (2007) the Court ruled that schools could, consistent with the First Amendment, restrict student speech at school-sponsored events, even events away from school grounds, if students promote "illegal drug use."
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Doug Watt
Not ready for 2012
12:55 AM on 03/04/2011
For decades the Phelps family protested at gay events and funerals and the public didn't consider it more than an opposing opinion. They finally figured out that they had to upset some straight people to get real attention and sure enough their case went to the Supreme Court.

Let me just say that all those people who were gay that Phelps attacked mercilessly as they died from AIDS were valuable good souls and didn't deserve to be treated so horribly.
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Christopher Hamilton
DC liberal, and proud of it!
02:33 PM on 03/04/2011
Agreed, this only got to the Public Outrage stage once straight people were targeted for the same crap that gay people have been dealing with for years. That's the ONLY good thing about this decision, that it will force straight people to deal with this crap for longer and MAYBE (just maybe) the American society at large will finally unify against the homophobic madness represented by the Westboro lunatics. I mean, give them a big enough stage and they drive away pretty much anyone with an actual soul. On the other hand, I honestly believe it's only a matter of time before violence breaks out at one of these protests, and the last thing I want to see is a Phelps clan sociopath claiming martyrdom on the evening news.
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Doug Watt
Not ready for 2012
03:45 PM on 03/04/2011
Well said, Christopher.
12:10 AM on 03/04/2011
I completely support this ruling. Although upsetting to some that it is acceptable by the law to protest a Marine's funeral, the precedent that this decision sets is valuable to every American. The Supreme Court's job is not to make moral decisions but rather interpret the law, and they were successful in sticking to that role. Anyone that protests this ruling should keep in mind that they are able to do so thanks to the right to free speech that Snyder v Phelps maintained.
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12:03 AM on 03/04/2011
You haven't yet figured out the difference between liberty and licence.

This decision was a victory for bullies.
Genders
Love, Tolerance, Enlightenment
11:51 PM on 03/03/2011
Time to go to their church and their homes and give em a taste of their own medicine.
12:43 AM on 03/04/2011
Considering there's maybe a hundred of them, I'm going to opt out and go have my nails done. You guys let me know what happens.

But seriously. This is a SMALL group. And they have so much of our attention WHY?

Okay, now I'm going to go have my nails done.
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11:10 PM on 03/03/2011
So I would be well within my first amendment rights to picket a WBC funeral with a sign that says "god hates dumb asses". Your witness.
11:50 PM on 03/03/2011
AWESOME idea!! F&F.
10:46 PM on 03/03/2011
Isn't it a form of child abuse to force children to hold up signs and participate in this brutal heartlessness. Surely they're going to need years of therapy once old man Phelps is gone. I wonder why they really do it.