In an 8–0 decision, the Court ruled in favor of "Hustler" magazine, holding that a parody ad published in the magazine depicting televangelist and political commentator Jerry Falwell Sr. as an incestuous drunk, was protected speech since Falwell was a public figure and the parody could not have been reasonably considered believable. Therefore, the Court held that the emotional distress inflicted on Falwell by the ad was not a sufficient reason to deny the First Amendment protection to speech that is critical of public officials and public figures. Constitutional limits to defamation liability cannot be circumvented for claims arising from speech by asserting an alternative theory of tort liability such as IIED.