Reply #117: Both, apparently. Invasion of privacy and emotional distress that resulted from the defamation

[A HERETIC I AM]

From http://www.kansas.com/611/story/216375.html

The jury decided that church members had caused plaintiff Albert Snyder "mental pain and suffering, fright, nervousness, indignity, humiliation, embarrassment and insult" when they picketed the March 2006 funeral of his son, Lance Cpl. Matthew A. Snyder, and later discussed Snyder's death on their Web site. Any family similarly targeted understands the elder Snyder's inclination to fight back.

And from http://www.baltimoresun.com/news/local/bal-westboro1031,0,7191706.story

The jury found the defendants liable for violating the Snyder family's expectation of privacy at the funeral and for intentionally inflicting emotional distress.