Snyder v. Phelps, et al., 580 F.3d 206 (4th Cir. 2009)

(defendant's signs declaring "Thank God for dead soldiers" and "Fag troops" displayed at funeral of Marine killed in Iraq are protected speech under the First Amendment - statements were rhetorical hyperbole that could not reasonably be interpreted as factual; court unanimously vacated trial court's $5 million verdict against defendant).