In "Snyder v. Phelps" (2011), It was argued that three criteria were necessary: immediacy, proximity, and instinctive (a reaction of the target, per Justice Ginsburg). Even "outrageous" and "hurtful speech" such as: “God Hates the USA/Thank God for 9/11,” “America is Doomed,” “Don’t Pray for the USA,” “Thank God for IEDs,” “Thank God for Dead Soldiers,” “Pope in Hell,” “Priests Rape Boys,” “God Hates Fags,” "Fags Doom Nations," “You’re Going to Hell,” and “God Hates You” is considered public debate, particularly when conducted on public land, and must enjoy "special" 1st Amendment protection. Lone dissenting Justice Samuel Alito likened the protests of the Westboro Baptist Church members to fighting words and of a personal character, and thus not protected speech. The majority disagreed and stated that the protesters' speech was not personal but public, and that local laws which can shield funeral attendees from protesters are adequate for protecting those in times of emotional distress.