The great thing about parody is that there are virtually no limits. Larry Flynt, God bless him, established this for us, with a little help from the nine old men. A 1983 edition of Hustler magazine, in a parody of a popular liquor ad of the time, depicted Jerry Falwell describing his first sexual encounter--with his mother, in an outhouse.
This item caused Falwell emotional distress. He sued Hustler on this basis. He won at the level of the 4th District Court of Appeals. And then the Supreme Court ruled unanimously against Falwell.
Can a public figure recover damages for libel and intentional infliction of emotional distress based on a satire, even a vicious satire?
No. The Court found that under the First Amendment, an obvious satire or parody of a public figure remains protected speech, even if it causes emotional distress to that person.
You probably know about the Fox vs. Franken lawsuit. And you probably know that a billion sources have said that Bill O'Reilly put Fox News up to it. O'Reilly, Fox's most popular on-air personality, was upset with Al Franken for humiliating him at a Los Angeles book expo in June by presenting documentary evidence of O'Reilly's frequent misrepresentations about his resume. O'Reilly said this about Franken on his radio show:
What this guy writes and says does not matter to me, other than...he insulted me in a forum where I was at a decided disadvantage, you know, he went over his time limit. It was very, very sneaky, and you know, as I said at the top of the broadcast, somebody calls you a liar to your face, you don't just laugh that off. That's an insult. In the old west, that woulda got you shot. See in the old west, and I woulda loved to have been in the old west, Al and I woulda just had a little, uh, a little shootout. You know? We woulda went out, on Wilshire Avenue, and uh, six shooters, now he's a much smaller target than I am, about four foot eleven, but he's wider, and it woulda been you know, Clint Eastwood time. I woulda had the cheroot, the serape, woulda given my squint, and I woulda put a bullet right between his head. Woulda been wrong, woulda been wrong, but it was the old west, and I would not have known any better, so I wouldn't have been held accountable because I would not have known any--now I do, now in 2003 that would have been wrong.
This is a news anchor for the most popular cable television news network fantasizing to hundreds of thousands of listeners about murdering a critic.