Snyder vs Phelps Case Study

Introduction

In what was an overwhelming victory for the freedom of speech, the Supreme Court on March 2, 2011, ruled that the First Amendment protected speakers even if the speech was outrageous. This was against lawsuits for intentionally inflicting emotional distress. Chief Justice Roberts provided the opinion of the Court in which eight members of the court (Scalia, Kennedy, Thomas, Ginsburg, Breyer, Sotomayor, Kagan, and Breyer) filed concurred opinions while it is only Alito J who filed a dissenting opinion. The court upheld the US Court of Appeals for the Fourth Circuits which was overturning the $5 million damages award to Snyder against the Westboro Baptist Church (WBC).

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In Snyder v. Phelps, 562 U.S. 443, the congregation of WBC led by Phelps and his daughters had picketed a military funeral of Snyder's son Corporal Matthew Snyder who had died in the line of duty in Iraq. WBC picketed to communicate its belief that God hated the US because of its tolerance of homosexuality, especially in the military. Also, the Church condemned the Catholic Church as there were continued scandals involving its clergy over the same. Fred Phelps with his followers picketed the funeral on public land approximately 1000 ft. from the church where the funeral was held in adherence to guidance from the local law enforcement officers. The picketers displayed signs expressing their views. Some of them read "Thank God for Dead Soldiers," "Fags Doom Nations," "America is Doomed," "Priests Rape Boys," "You're going to hell." The picketing took place for about 30 minutes before the funeral commenced. The petitioner, Matthew Snyder's father was able to see the tops of the picketer's signs when driving to the funeral but was not able to read what was written on the signs and until later that evening in the news broadcast.

Snyder filed a case against Phelps, his participant daughters and the entire WBC for defamation, publicity given to private life, inflicting emotional distress, intrusion upon seclusion, and civil conspiracy. Upon listening to the allegation, the federal district court had issued a summary judgment to defamation and publicity given to private life. However, the other three accusations proceeded to the jury that awarded Snyder $2.9 million in compensatory for damages. Also, $ 2.1 million was awarded for punitive damages. WBC challenged the ruling and sought the judgment to be made on the ground of the First Amendment. Despite reducing the punitive damage award, the District Court upheld the ruling and left the verdict intact. Upon appeal to the Fourth Circuit, the verdict was reversed based on First Amendment, with the jury stating that Westboro's statements concerned public matters, and were expressed solely through hyperbolic rhetoric.

Snyder was dissatisfied with the ruling and appealed the case to the US Supreme Court; however, the court affirmed verdict of the appeals court. Writing for the majority of the members of the jury, Chief Justice Roberts stressed that the defendant's (Phelps and WBC) statements purely touched on the matters of the public importance adding that the picketers conducted themselves peacefully under the guidance from local enforcement officers. While addressing the intentional infliction of emotional distress allegations, Chief Justice concentrated on the requirement of the outrageousness. He referred to the Hustler Magazine, Inc. v. Falwell (1988) which follows the principle that outrageousness is a "highly malleable standard" too subjective when applied to the matters of public concern.

On intrusion claim in which Snyder had claimed to have been held a captive audience to the offensive and vile messages of the defendants, Roberts pointed out that Westboro kept a safe distance away from the funeral (1000 ft.) a location which was arranged by the law enforcement and by Maryland statutes. Roberts also added that a captive audience only applied to protect the privacy rights of the homeowners. Snyder had confessed to having not been able to read the WBC's signs and just learned of their content later that evening in the news broadcast which was after the funeral was concluded. The court also rejected the civil conspiracy claim.

Conclusion

In a concluding statement, Chief justice Roberts said that speech is powerful as it can stir people to action, move them to tears both of joy and sorrow and as it did in the case before them inflict great pain, but basing on the fact before them, they could not respond to that pain by punishing the speaker. He added that as a Nation they decided to choose a different course of protecting even hurtful speech on the public issues to ensure that they do not stifle public debate.

Personal Opinion

The Court demonstrated its exceptional commitment to protecting freedom of speech regardless of the content or viewpoint. There are some situations which may undermine the robustness of protecting the rights of free speech. The court gave much focus on the importance of public discourse as a rationale for protecting freedom of speech, the protected status of the private speech cannot be fully recognized. Determining whether the expression is public or private based on the content of the speech and where it is spoken remains unclear which is a potential concern is.

Works Cited

Martin, J., M. Snyder v. Phelps. Applying the constitution's historic protection of offensive expression to religiously motivated speech, 2011, pp. 1-28.