Westboro Baptist Church

Westboro Baptist Church
Theology Primitive Baptist
Region Topeka, Kansas
Founder Fred Phelps (deceased)
Members 40[2]
Official website godhatesfags.com

Westboro Baptist Church (WBC) is a Baptist church which is known for its hate speech, especially against LGBT people (homophobia), Catholics (anti-Catholicism), Orthodox Christians (anti-Orthodoxy), Muslims (Islamophobia), Jews (anti-Judaism/religious antisemitism), American soldiers and politicians.[3][4] The church is widely known as a hate group[5] and is monitored as such by the Anti-Defamation League and the Southern Poverty Law Center. The church has been involved in actions against gay people since at least 1991, when it sought a crackdown on homosexual activity at Gage Park six blocks northwest of the church.[6] In addition to conducting anti-gay protests at military funerals, the organization pickets celebrity funerals and public events.[7] Protests have also been held against Jews and Catholics, and some protests have included WBC members stomping on the American flag and/or flying the flag upside down on a flagpole. The church also has made statements such as, "thank God for dead soldiers," "God blew up the troops," "thank God for 9/11," and "God hates America."[8]

The church is headquartered in a residential neighborhood on the west side of Topeka about 3 miles (5 km) west of the Kansas State Capitol. Its first public service was held on the afternoon of November 27, 1955.[9] The church was headed by Fred Phelps before his death in March 2014, though church representatives said the church had had no defined leader for some time before his death.[10] The church consists primarily of members of Phelps's extended family,[11] and in 2011, the church stated that it had about 40 members.[2]

The WBC is not affiliated with any Baptist denomination, although it describes itself as Primitive Baptist and following the five points of Calvinism.[1] The Baptist World Alliance and the Southern Baptist Convention (the two largest Baptist denominations) have both denounced the WBC over the years.[12] In addition, other mainstream Christian denominations, such as the Methodist Church and Baptist Church have condemned the actions of the independent Westboro Baptist Church.[13]


Advertisement for opening service of Westboro Baptist Church, Topeka Capital, 1955

Westboro Baptist Church originated as a branch of the East Side Baptist Church,[14] established in 1931 on the east side of Topeka.[15] In 1954, East Side hired Fred Phelps as an associate pastor, and then promoted him to pastor of their new church plant, Westboro Baptist, which opened in 1955 on the west side of Topeka.[14] Soon after Westboro was established, Phelps broke ties with East Side Baptist.

Westboro Baptist began picketing Gage Park in Topeka in 1991, saying it was a den of anonymous homosexual activity. Soon, their protests had spread throughout the city, and within three years the church was traveling across the country.[16] Phelps explained in 1994 that he considered the negative reaction to the picketing to be proof of his righteousness.[17]

On August 20, 1995, a pipe bomb exploded outside the home of Shirley Phelps-Roper, the daughter of Fred Phelps. The blast damaged an SUV, a fence, and part of the house, but no one was injured. In 1996, two men were arrested for the bombing, and both admitted to causing the blast. They had believed that Phelps-Roper's house was that of the pastor, and wanted to retaliate against Westboro's anti-gay protests at Washburn University. One of the bombers was fined $1,751 and was sentenced to 16 days in prison plus 100 hours of community service.[18]

Fred Phelps died of natural causes shortly before midnight on March 19, 2014.[19][20][21] His daughter Shirley said that a funeral for her father would not be held because Westboro does not "worship the dead".[21]

Protest activities

WBC pickets approximately six locations every day, including many in Topeka and some events farther afield. On Sundays, up to 15 churches may receive pickets.[22][23] By their own count, WBC has picketed in all 50 U.S. states.[24]

The group carries out daily picketing in Topeka and travels nationally to picket the funerals of gay victims of murder, gay-bashing or people who have died from complications related to AIDS; other events related or peripherally related to homosexuality; Kansas City Chiefs football games; and live pop concerts. As of March 2009 the church claims to have participated in over 41,000 protests in over 650 cities since 1991.[25] One of Westboro's followers estimated that the church spends $250,000 a year on picketing.[26]

The pickets have resulted in several lawsuits. In 1995, Phelps Sr.'s eldest grandson, Benjamin Phelps, was convicted of assault and disorderly conduct after spitting upon the face of a passerby during a picket.[27] In the 1990s the church won a series of lawsuits against the City of Topeka and Shawnee County for efforts taken to prevent or hinder WBC picketing, and was awarded approximately $200,000 in attorney's fees and costs associated with the litigation. In 2004, Phelps Sr.'s daughter Margie Phelps and Margie's son Jacob were arrested for trespassing, disorderly conduct and failure to obey after disregarding a police officer's order during an attempted protest.[28] In response to pickets at funerals, Kansas passed a law prohibiting picketing at such events. In the autumn of 2007, the father of a Marine whose funeral was picketed by the WBC was awarded $5 million in damages.[29][30] The award was later overturned on appeal by the Fourth Circuit Court of Appeals in a decision upheld by the Supreme Court in Snyder v. Phelps. In June 2007 Shirley Phelps-Roper was arrested in Nebraska and charged with contributing to the delinquency of a minor. The arrest resulted from her allowing her ten-year-old son to step on the American flag during the demonstration, which is illegal under Nebraska law. The defense contended that the child's actions were protected speech, and that the state law is unconstitutional. The prosecution claimed the demonstration was not intended as political speech, but as an incitement to violence, and that Phelps-Roper's conduct might also constitute child abuse. Prosecutors later dropped charges against Phelps-Roper.[31]

On two occasions, the church accepted offers for radio air time in exchange for canceling an announced protest.[32][33]

Anti-gay picketing

While being filmed by documentary maker Louis Theroux, they picketed a local appliance store because it sold Swedish vacuum cleaners, which the church viewed as being supportive of gay people because of Swedish prosecution of Åke Green, a pastor critical of homosexuality.[34]

Picketing in Topeka, with the group's signature multi-colored picket signs.

The church has picketed or threatened to picket the productions of The Laramie Project, a play based on the murder of Matthew Shepard (whose funeral they also picketed).[35][36]

On January 25, 2004, Phelps picketed five churches (three Catholic and two Episcopalian) and the Federal Courthouse for what he said was their part in legitimizing same-sex marriages in Iowa. A community response was to hold counter-protests and a multifaith service in the municipal auditorium.[37] On January 15, 2006, Westboro members protested a memorial for Sago Mine disaster victims, claiming that the mining accident was God's revenge against America for its tolerance of homosexuality.[38]

The Westboro Baptist Church celebrated the 2016 terrorist attack on an Orlando gay night club that resulted in forty-nine people murdered and fifty-three others wounded.[39][40]

Funeral pickets

The group came into the national spotlight in 1998, when it was featured on CNN for picketing the funeral of Matthew Shepard, a young man from Laramie, Wyoming who was beaten to death by two men, allegedly because of his homosexuality.[41] Since then, the church has attracted attention for many more actual and planned funeral pickets.[42][43][44][45][46][47]

In July 2005, the Westboro Baptist Church declared its intention to picket the memorial service of Carrie French in Boise, Idaho. French, 19, was killed on June 5 in Kirkuk, Iraq, where she served as an ammunition specialist with the 116th Brigade Combat Team's 145th Support Battalion. Phelps Sr. said, "Our attitude toward what's happening with the war is the Lord is punishing this evil nation for abandoning all moral imperatives that are worth a dime."[48]

In 2006, Westboro picketed with banners saying "God hates fags" and "Thank God for dead soldiers" at the Westminster, Maryland, funeral of Matthew Snyder, a U.S. Marine who was also killed in Iraq.[49] Ruling on a subsequent lawsuit filed by Snyder's father, Albert Snyder, the U.S. Supreme Court decided, 8–1 in Snyder v. Phelps, that Westboro's actions constituted protected free speech.[50]

On February 2, 2008, the group picketed during the funeral of former The Church of Jesus Christ of Latter-day Saints president Gordon B. Hinckley in Salt Lake City, Utah, displaying picket signs accusing him of being a "lying false prophet" and "leading millions of people astray".[51] The organization also criticized Hinckley for being too accepting of gay people, accusing him of having an ambiguous voice about homosexuality rather than taking a firm stand against it.[52] Police had difficulty determining whether the demonstration met the guidelines of protected free speech.[51]

Westboro picketed the funeral of recording artist Michael Jackson after his death on June 25, 2009.[53][54] Members of Westboro have also recorded a song titled "God Hates the World", an adaptation of Jackson's charity single "We Are the World".[55]

In May 2010, Westboro picketed the funeral of heavy metal vocalist Ronnie James Dio in Los Angeles, saying that they believed the singer worshipped Satan.[56] Dio's widow urged attendees to ignore the protest, saying "Ronnie hates prejudice and violence. We need to turn the other cheek on these people that only know how to hate someone they didn't know. We only know how to love someone we know."[57]

In January 2011, Westboro announced that they would picket the funeral of Christina Green, a 9-year-old victim of the 2011 Tucson shooting in which Representative Gabrielle Giffords was also (non-fatally) shot. In response, the Arizona legislature passed an emergency bill to ban protests within 300 feet (91 m) of a funeral service, and Tucson residents made plans to shield the funeral from protesters.[58][59] The church canceled plans to hold a protest during the memorial at the University of Arizona in exchange for air time on radio talk shows.[60] According to university officials, between 700 and 1,200 students amassed to counter four WBC picketers who appeared at the campus after the event.[61] Jael Phelps explained to Louis Theroux in her America's Most Hated Family in Crisis interview that she and the other members of the WBC picketed at the funeral of a Muslim man's wife simply because the man had witnessed and scolded them for intentionally burning a copy of the Quran in public a week earlier.[62]

On October 5, 2011, Fred Phelps' daughter, Margie, announced via her Twitter account that the church would be picketing Apple Inc. founder Steve Jobs' funeral.[63][64] CBS News and The Washington Post noted the irony in the fact that Margie used an iPhone to create the tweet.[64][65]

The church announced on December 16, 2012, that it would be picketing at the funerals of the victims of the Sandy Hook Elementary School shootings.[66]

On April 15, 2013, the church posted a press release to its Twitter account in which it thanked God for that day's Boston Marathon bombings, and announced its plan to "picket the funeral of those killed". Pointing out that the federal government is classifying the bombings as a terrorist attack, yet is being unclear about whether it is of a "domestic or foreign nature", the release went on to claim to answer the question with, "Here's a hint — GOD SENT THE BOMBS! How many more terrifying ways will you have the LORD injure and kill your fellow countrymen because you insist on nation-dooming filthy fag marriage?!" By early the next morning, nearly 4,000 people had signed a We the People petition on the White House website asking for the banning of such demonstrations by the church at victims' funerals. Additionally, a posting that same day on a Twitter account affiliated with the hacktivist group Anonymous hinted that Church leaders would be targeted if they made good on their threat to picket the funerals.[67]

On May 20, 2013, the church tweeted praising God for the 2013 Moore tornado and that they would protest the funerals of the victims.[68]

Members of the group intended to picket the March 2015 funeral of actor Leonard Nimoy but were unable to find the location.[69]

On June 18, 2016, members of the church picketed after the 2016 Orlando nightclub shooting that resulted in 50 deaths at a nightclub frequented by members of the Orlando LGBT community, but around 200 people blocked view of the picketing.[70]

Protests against Jewish institutions

A protest against Jews, held by the Westboro Baptist Church.

In 1996 Phelps led a protest at the United States Holocaust Memorial Museum in Washington, D.C., proclaiming:

Whatever righteous cause the Jewish victims of the 1930s–40s Nazi Holocaust had (probably minuscule, compared to the Jewish Holocausts against Middle Passage Blacks, African Americans and Christians—including the bloody persecution of Westboro Baptist Church by Topeka Jews in the 1990s), has been drowned in sodomite semen. American taxpayers are financing this unholy monument to Jewish mendacity and greed and to filthy fag lust. Homosexuals and Jews dominated Nazi Germany ... The Jews now wander the earth despised, smitten with moral and spiritual blindness by a divine judicial stroke ... And God has smitten Jews with a certain unique madness ... Jews, thus perverted, out of all proportion to their numbers energize the militant sodomite agenda... Jews are the real Nazis.[71]

WBC was present at a 2002 Holocaust memorial dedication in Topeka, proclaiming "God Hates Reform Judaism".[72]

On May 8, 2009, members of the church protested at three Jewish sites in Washington, D.C., including the Anti-Defamation League (ADL) offices, the U.S. Holocaust Memorial Museum and the city's largest synagogue. Margie Phelps, daughter of Pastor Fred Phelps, led the protest, holding signs stating that "God Hates Israel", "Jews Killed Jesus", "America Is Doomed", "Israel Is Doomed", and "ADL Jew Bullies". The protest was apparently part of a series of upcoming protests which the church has planned at Jewish institutions in Omaha, St. Louis, South Florida and Providence. The group reportedly posted a list of the upcoming protests' locations and dates, along with the statement "Jews Killed the Lord Jesus."[73]

In an interview, Margie Phelps said that her church was targeting the American Jewish community because church members had "testified" to Gentiles for 19 years that "America is doomed" and that "Now it's too late. We're done with them." She also claimed that Jews were "one of the loudest voices" in favor of homosexuality and abortion, and that "[Jews] claim to be God's chosen people. Do you think that God is going to wink at that forever?" Phelps concluded by stating, in an apparent reference to the Book of Revelation, that all the nations of the world would soon march on Israel, and that they would be led by President Barack Obama, whom she called the "Antichrist".[73]

Other protest activities

On January 26, 2008, WBC traveled to Jacksonville, North Carolina, home of Camp Lejeune, to protest the United States Marine Corps in the wake of the murder of Maria Lauterbach. Five women protested, stomping on the American flag and shouting slogans such as "1,2,3,4, God Hates the Marine Corps".[74]

On May 14, 2008, two days after the 2008 Sichuan earthquake which claimed the lives of at least 70,000 people, WBC issued a press release thanking God for the heavy loss of life in China, and praying "for many more earthquakes to kill many more thousands of impudent and ungrateful Chinese".[75]

Most anti-abortion activists avoided the funeral of OB/GYN Dr. George Tiller, assassinated on May 31, 2009. Held at the Wichita College Hill United Methodist Church, it was attended by 900 mourners. However, 17 members from Westboro picketed, kept at a 500-foot distance by police. The WBC protesters held signs that read "God sent the shooter", "Abortion is bloody murder", and "Baby Killer in Hell".[76][77]

On May 29, 2011, the WBC intended to protest in Joplin, Missouri, at the memorial service for the victims of the May 22, 2011, tornado that leveled large portions of that town.[78] Those intending to protest the memorial service or President Obama's speech given there, or both, were refused entry into the venue by hundreds of local and regional residents,[79] including a large group of bikers from the Patriot Guard Riders.[80]

On May 30, 2011, the WBC was present at Arlington National Cemetery's Memorial Day services as part of their "Thank God for Dead Soldiers" campaign. A counter protest included members of the Ku Klux Klan.[81]

Eleven-year-old brain tumor victim Harry Moseley raised £500,000 for charity but Marge Phelps of the Westboro Baptist Church criticized his family for not teaching him to "obey God". This comment within a few hours of the boy's death caused great distress to the bereaved.[82]

The WBC announced its intent to protest on December 19, 2012, at funerals of victims of the Sandy Hook Elementary School shooting. The online hacktivist group Anonymous and several other groups responded by organizing a human wall to shield the victims' families. The WBC then left the area without engaging in any protests.[83]


The church has occasionally issued press releases threatening to picket sensitive events such as funerals and memorials without following through. Examples include the funerals of Natasha Richardson,[84] Elizabeth Taylor,[85] Ryan Dunn,[86] Joe Paterno,[87] Roy Tisdale,[88] Yeardley Love,[89] Charlie and Braden Powell,[90] Steve Jobs,[64] Whitney Houston,[91] George Jones,[92] Lou Reed,[93] Pete Seeger,[94] Maya Angelou,[95] Robert H. Schuller,[96] Slayer guitarist Jeff Hanneman,[97] Robin Williams,[98] and victims of the I-35W Mississippi River bridge collapse.[99] Margie Phelps later claimed over Twitter to have protested Houston's funeral and uploaded an image showing WBC protestors there. However, Star-Ledger reporters later stated that no WBC protestors had been present,[100] leading to allegations of photo manipulation.[101]

Church views

A WBC member and child protesting homosexuality at the Trinity Episcopal Church in Tulsa, Oklahoma

The Westboro Baptist Church considers membership in most other religious groups, such as the Roman Catholic Church or Islam, as akin to devil worship, and states these other churches to be "Satanic frauds preaching Arminian lies".[102] The church defines itself as "Old School (or, Primitive) Baptist" and sees itself as defending the Five Points of Calvinism: total depravity, unconditional election, limited atonement, irresistible grace, and perseverance of the saints.[103] Rebecca Barrett-Fox, a professor at Arkansas State University who completed a dissertation on Westboro Baptist, has labelled it as "hyper-Calvinist".[104]


In the BBC documentary The Most Hated Family in America, filmmaker Louis Theroux questioned Shirley Phelps-Roper as to whether she had considered that Westboro's technique of protests were more likely to "put people off the Word of Jesus Christ and the Bible". In response, Phelps-Roper said, "You think our job is to win souls to Christ. All we do, by getting in their face and putting these signs in front of them and these plain words, is make what's already in their heart come out of their mouth."[105] Later in the documentary, Phelps-Roper agrees that the $200,000 the church annually spends to fly to funerals to protest was money spent to spread "God's hate".[105]


The church is noted for its anti-homosexual rhetoric[106][107] and runs numerous web sites such as GodHatesFags.com, GodHatesAmerica.com, and others expressing condemnation of homosexuality.

The group bases its work on the belief expressed by its best known slogan and the address of its primary web site, God Hates Fags, asserting that every tragedy in the world is linked to homosexuality—specifically society's increasing tolerance and acceptance of the so-called homosexual agenda. The group maintains that God hates those who engage in homosexual activity above all other kinds of "sinners"[108] and that homosexuality should be a capital crime.[109]

Their views on homosexuality are partially based on teachings found in the Old Testament, specifically Leviticus 18:22 and 20:13, which they interpret to mean that homosexual behavior is detestable, and that homosexuals should be put to death.[108]



The Westboro Baptist Church refers to Catholic priests as "vampires" and "Draculas" and accuses Catholic priests of sucking semen out of male children's genitals like vampires suck blood from their victims. In addition, WBC called Pope Benedict XVI such epithets as "The Godfather of Pedophiles" and the "Pervert Pope". In April 2008 the WBC protested against Pope Benedict XVI during a papal visit in New York City.

WBC member protesting Pope Benedict XVI outside the United Nations in New York City (2008).

The WBC launched a website called Priests Rape Boys in which they criticize the Roman Catholic Church because of the Catholic sex abuse scandal, saying, "Every time any person gives any amount of money to the Catholic Church, that person is paying the salary of pedophile rapists."[110]

The WBC describes the Roman Catholic Church as "the largest, most well-funded and organized pedophile group in the history of man"[111] and goes on to say that, "There are over 1 billion Catholics in the world—that's one out of every six people alive today—and every single one of them will split Hell wide open when they die—period. And there is nothing they can do about it."[110] The WBC also criticizes Catholicism, as it does Eastern Orthodoxy, for venerating the Virgin Mary, the Saints, relics, and icons; they accuse the Catholic Church of committing idolatry.


Though the main purpose of the Priests Rape Boys website is to criticize Catholicism, the WBC also criticizes several mainline Protestant churches on the website, including Methodists, Presbyterians, Lutherans, Anglicans, and Baptists. The WBC states that

...their preachers have shirked their responsibility to tell people the truth about sin, and instead lie to them about what the Lord their God doth require of them. If these lying, false prophets told people the truth about what God says regarding those who suffer sin upon their neighbor (Lev. 19:17–18), there wouldn't be any butts in the seats when the plate got passed. These preachers are not preachers of righteousness, they are teachers having itching ears (2Tim 4:3), and they absolutely count on the abysmal bible illiteracy of their parishioners ... "Priests rape boys" is indeed an air-tight, three word case against all of the mainline "christian" churches – their preachers and members, without exception. They are all going to Hell![112]

Eastern Orthodoxy

See also: Anti-Orthodoxy

The WBC claims that Orthodox Christians are indistinguishable from Roman Catholics. The WBC criticizes the Eastern Orthodox Church's use of icons, claiming that they constitute idolatry. The WBC also criticizes veneration of the Virgin Mary (aka the Theotokos), saying, "There is no scripture that supports bowing down to kiss images ... or praying to Mary! She was a human being, who God predestinated to bring forth the Lord Jesus Christ, and to raise him."[113]

Oriental Orthodoxy

The WBC claims that Ethiopian Orthodoxy is "grounded in a big, fat lie" and is "a strange co-mingling of Jewish and pagan rituals".[114] WBC also claims that because the Orthodox churches are in full communion with one another, they are not "true New Testament churches", since WBC claims that a true church must be "independent, local, autonomous, and without any formal affiliation with other churches". The WBC also condemns the teaching of theosis or glorification in Orthodox Christianity, saying "Stop glorifying the creature!"[115]


In response to a Newsweek article alleging that American soldiers flushed copies of the Qur'an down the toilet at Camp X-Ray in Guantanamo Bay, Fred Phelps released this statement:[116]

So what if our guys flushed copies of the Quran down the toilet? We hope they did. They probably did; We hope they flush more. Mohammed was a demon-possessed whoremonger and pedophile who contrived a 300-page work of Satanic fiction: The Quran! Like America's own whoremonger and pedophile wangled his own hokey Book of Mormon!

In relation to the Iraq War, a WBC flyer says "America bombed our church with an IED made by fag students... In His retaliatory rage God is killing Americans with Muslim IEDs: 'Saying, Touch not my anointed, and do my prophets no harm.' 1 Chron 16:22."[117]

In the 2011 documentary America's Most Hated Family in Crisis by Louis Theroux, Jael Phelps said in an interview that she and the other members of the WBC tauntingly and publicly burned a copy of the Quran while being scolded by a Muslim man, calling it an "idolatrous piece of trash" and that they were giving it the "proper respect that it deserves" by doing so.[62] They picketed the funeral of the Muslim man's wife the following week. Jael Phelps said that the wife's death was partly due to her Muslim husband having spoken out against the WBC, and therefore rejecting God and bringing his "righteous judgement" down upon him. She also commented that "all those angry little Muslims can just shut their mouths."[118]


The WBC maintains a God Hates India webpage where they state "80% of India's population claim to practice Hinduism. Nuff said. A country full of idolatry inevitably results in a nation full of fags and fag-enablers, because that's what happens when you depart from the Living God!"[119]

The WBC then admonishes Hindus to convert to Christianity saying: "If you would STOP worshipping false gods, being a fag would not be a complex matter. Stop going a whoring after other gods and start serving the Living God in truth!"[119]


In the section about Jews, the WBC FAQ states:

The only true Jews are Christians. The rest of the people who claim to be Jews aren't, and they are nothing more than typical, impenitent sinners ... the vast majority of Jews support fags. In fact, it is the official policy of Reformed Jews to support same-sex marriage. Of course, there are Jews who still believe God's law, but most of them have even departed from that. It doesn't matter if you're a Jew or a Gentile...as long as you believe in Christ.[120]

They also blame the Jews for killing Christ, citing 1 Thessalonians 2:14–15 as justification.[120]

In 1996, Phelps began a campaign called "Topeka's Baptist Holocaust", whereby he attempted to draw attention to attacks perpetrated against WBC picketers, saying that they were not random but organized attacks orchestrated by Jews and homosexuals. Phelps announced, "Jews killed Christ", and "Fag Jew Nazis are worse than ordinary Nazis. They've had more experience. The First Holocaust was a Jewish Holocaust against Christians. The latest Holocaust is by Topeka Jews against Westboro Baptist Church."[121]

In another statement, he said "Topeka Jews today stir up Kansas tyrants in persecuting Westboro Baptists. They whine about the Nazi Holocaust, while they perpetrate the Topeka Holocaust."[121]

A March 25, 2006 flier regarding a Jewish adversary of Phelps uses the phrase "bloody Jew" four times and the phrase "evil Jew" more than once every 12 sentences. The Anti-Defamation League has criticized the church and Phelps,[122] and keeps a sampling of WBC's fliers regarding Judaism on their website.[123]

The WBC has described the Holocaust as God's punishment on Jews.[124]


The church's founder, Fred Phelps, was a veteran of the Civil Rights movement in the 1960s.[125] The Church's disapproval of racism and the use of physical violence by groups such as neo-Nazis and the KKK is stated on its website. The site's FAQ page states, "[W]e don't believe in physical violence of any kind, and the Scripture doesn't support racism. ... The only true Nazis in this world are fags."[126]

The Church has previously condemned particular nations, such as Italy, which it described as a nation of "mobster-breeding perverts"[127] and Australia, which it describes as the "land of the sodomite damned".[128]

Westboro announced its intent to picket the funeral of Nelson Mandela, the hero of the anti-apartheid movement, claiming that he was going to hell for committing adultery by remarrying after his divorce. They also condemned the Dutch Reformed Church for having promoted apartheid.[129][130]

Barack Obama

The Westboro Baptist Church believes that Barack Obama is the Antichrist and that he forms an unholy trinity with Satan and former Pope Benedict XVI, whom they believe is the False Prophet of Revelation.[131]

Margie Phelps, daughter of pastor Fred Phelps and attorney for WBC, said in an interview with Fox News that Obama is "absolutely" going to Hell and that he is "most likely the Beast spoken of in the Revelation". She also said Obama's presidency is a sign of the Apocalypse.[132]


Laws limiting funeral protests

In response to the protests conducted by Westboro members at Indiana funerals, a bill was introduced in the Indiana General Assembly that would make it a felony to protest within 500 feet (150 m) of a funeral. The bill provides penalties of up to three years in prison and a $10,000 fine for those found to be in violation of the law. Shortly before this bill was signed members of the church had threatened to protest in Kokomo, Indiana, at a funeral service that was being held for a soldier who was killed in Iraq. On January 11, 2006, the bill unanimously (11–0) passed a committee vote,[133] and while members of the church had traveled to Kokomo to protest, they were not seen during or after the funeral service. On May 23, 2006, the state of Michigan banned any intentional disruption of funerals within 500 feet (150 m) of the ceremony. Violating the statute would be a felony, punishable by up to two years in prison and a $5,000 fine for the first offense and up to four years in prison and a $10,000 fine for a subsequent offense.[134]

On May 17, 2006, the state of Illinois enacted Senate Bill 1144, the "Let Them Rest In Peace Act", to shield grieving military families from protests during funerals and memorial services of fallen military service members. A first-time violation of the Act is a Class C misdemeanor, punishable by up to 30 days in jail and a $1,500 fine and a Class 4 felony for a second or subsequent offense, which is punishable by one to three years in state prison and a fine of up to $25,000.[135]

On May 29, 2006, President George W. Bush signed into law the Respect for America's Fallen Heroes Act (Pub.L. 109–228), prohibiting protests within 300 feet (91 m) of the entrance of any cemetery under control of the National Cemetery Administration from 60 minutes before to 60 minutes after a funeral.[136] Penalties for violating the act are up to $100,000 in fines and up to one year imprisonment.[136] The bill garnered overwhelming bipartisan support in Congress with a 408–3 vote in the House, with 21 not voting, and a unanimous vote in the Senate.[136]

On January 11, 2011, the state of Arizona held an emergency legislative session to pass a bill barring protests within 300 feet (91 m) of a funeral and within an hour from its beginning or end. The bill was swiftly signed into law ahead of the January 12 funeral of those killed in the 2011 Tucson shooting.[137][138]

On August 2, 2012, Congress passed a bill that included restrictions on demonstrators at military funerals, which became law four days later when signed by President Obama. The bill says that for 2 hours before until 2 hours after the funeral service demonstrators must stay at least 300 feet (91 m) away from the boundary of the funeral location and away from the residence of grieving family members.[139]

Supreme Court case

Main article: Snyder v. Phelps

On March 10, 2006, WBC picketed the funeral of Marine Lance Corporal Matthew A. Snyder in Westminister, Maryland.[140][141][142] The picket was held in a location cordoned off by the police, approximately 1,000 feet (300 m) from the Church, for about 30 minutes before the funeral began.[143] On June 5, 2006, the Snyder family sued for defamation, invasion of privacy, and intentional infliction of emotional distress.[144] The lawsuit named Albert Snyder, Matthew Snyder's father, as plaintiff and Fred W. Phelps, Sr.; Westboro Baptist Church, Inc.; Rebekah Phelps-Davis; and Shirley Phelps-Roper as defendants, alleging that they were responsible for publishing defamatory information about the Snyder family on the Internet, including statements that Albert and his wife had "raised [Matthew] for the devil" and taught him "to defy his Creator, to divorce, and to commit adultery". Other statements denounced them for raising their son Catholic. Snyder further complained the defendants had intruded upon and staged protests at his son's funeral. The claims of invasion of privacy and defamation arising from comments posted about Snyder on the Westboro website were dismissed on First Amendment grounds, but the case proceeded to trial on the remaining three counts.[145][146] At the trial, Albert Snyder testified:

They turned this funeral into a media circus and they wanted to hurt my family. They wanted their message heard and they didn't care who they stepped over. My son should have been buried with dignity, not with a bunch of clowns outside.[147]

In his instructions to the jury, U.S. District Judge Richard D. Bennett stated that the First Amendment protection of free speech has limits, including vulgar, offensive and shocking statements, and that the jury must decide "whether the defendant's actions would be highly offensive to a reasonable person, whether they were extreme and outrageous and whether these actions were so offensive and shocking as to not be entitled to First Amendment protection".[148] See also Chaplinsky v. New Hampshire, a case where certain personal slurs and obscene utterances by an individual were found unworthy of First Amendment protection, due to the potential for violence resulting from their utterance.

On October 31, 2007, WBC, Fred Phelps and his two daughters, Shirley Phelps-Roper and Rebecca Phelps-Davis, were found liable for invasion of privacy and intentional infliction of emotional distress. A federal jury awarded Snyder $2.9 million in compensatory damages, then later added a decision to award $6 million in punitive damages for invasion of privacy and an additional $2 million for causing emotional distress (a total of $10,900,000). The organization said it would not change its message because of the verdict.[149][150][151] WBC said that it was thankful for the verdict,[152] but also unsuccessfully sought a mistrial (based on alleged prejudicial statements made by the judge and violations of the gag order by the plaintiff's attorney)[153] and also filed an appeal.

On February 4, 2008, U.S. District Judge Richard D. Bennett upheld the ruling, but reduced the punitive damages from $8 million to $2.1 million, bringing the total judgment to $5 million.[154] Liens were ordered on church buildings and Phelps' law office in an attempt to ensure that the damages would be paid.[155]

On September 24, 2009, a federal appeals court ruled in favor of Westboro Baptist Church and reversed the lower court's award. It found their picket near the funeral is protected speech because it involves "matters of public concern, including the issues of homosexuals in the military, the sex-abuse scandal within the Catholic Church, and the political and moral conduct of the United States and its citizens", and did not violate the privacy of the service member's family.[156] On March 30, 2010, the appeals court ordered Albert Snyder to pay the church's court costs of over $16,000, a move that Snyder's attorney's referred to as "adding insult to injury".[157] The decision led to nationwide support for Snyder, with over 3,000 promises for donations to help offset the cost; political commentator Bill O'Reilly offered to pay the entire amount of the costs on March 30.[158][159] The American Legion has also raised $17,000 to help pay Snyder's court costs.[160]

On March 8, 2010, the U.S. Supreme Court granted certiorari in Snyder v. Phelps, (Docket No. 09-751, March 8, 2010).[161] On May 28, Senate Majority Leader Harry Reid, joined by 42 other Senators, filed an amicus brief in support of Snyder with the Supreme Court. On June 1, Kansas Attorney General Stephen Six filed a separate brief supporting Snyder. This brief was joined by the Attorneys General of 47 other states and the District of Columbia, with Maine and Virginia being the two exceptions.[162][163] Several news and civil rights organizations filed amicus briefs in support of Phelps, including the American Civil Liberties Union,[164] the Reporters Committee for Freedom of the Press, and twenty one other media organizations.[165]

In an 8–1 decision, the Supreme Court ruled in favor of Phelps on March 2, 2011. Chief Justice John Roberts wrote the majority opinion stating: "What Westboro said, in the whole context of how and where it chose to say it, is entitled to 'special protection' under the First Amendment and that protection cannot be overcome by a jury finding that the picketing was outrageous."[166] Justice Samuel Alito, the lone dissenter, said Snyder wanted only to "bury his son in peace". Instead, Alito said, the protesters "brutally attacked" Matthew Snyder to attract public attention. "Our profound national commitment to free and open debate is not a license for the vicious verbal assault that occurred in this case," he said.[167]

On July 14, 2006, Mundy Township, Michigan billed the WBC for $5,000. The Westboro church had informed township authorities on June 28 that a protest was planned at the Swartz Funeral Home. The bill to the church ensued, according to the local police chief, because the congregation failed to keep a verbal contract for security. Fred Phelps' daughter claimed that the Holy Ghost had informed them not to fly to Michigan even though they had already purchased airline tickets. Security at the Webb funeral was high; 15 fire trucks were involved, as well as numerous police officers from nearby jurisdictions.[168] The township has now stated that it will not pursue the matter.

Canadian entry ban

In August 2008, Canadian officials learned of the WBC's intent to stage a protest at the funeral of Tim McLean, a Winnipeg resident killed on a bus. The protests intended to convey the message that the man's murder was God's response to Canadian laws permitting abortion, homosexuality, divorce and remarriage. In response, Canadian officials barred the church's members from entering the country.[169]

UK entry ban

In February 2009, British news sources[170] discovered that WBC had announced on their website that they intended to picket a youth production of The Laramie Project to be held at Central Studio, Queen Mary's College in the town of Basingstoke, Hampshire, on February 20, 2009. This would have been their first ever picket in the United Kingdom.[171]

On the lead-up to the picket, a number of MPs, lobby groups and LGBT groups appealed to the British Home Secretary, Jacqui Smith,[172] requesting these individuals be blocked from entering the UK,[173] on the basis that WBC would be inciting hatred towards LGBT people. On February 18, 2009, two days before the intended picket date, the Home Office announced that Fred Phelps and Shirley Phelps-Roper would be specifically excluded from entering the UK for having "engaged in unacceptable behaviour by inciting hatred against a number of communities", and that "other church members could also be flagged and stopped if they tried to enter Britain".[174][175][176]

An alliance of six British religious groups (the Baptist Union of Great Britain, Evangelical Alliance UK, Faithworks, Methodist Church of Great Britain, United Reformed Church and Bible Society-funded thinktank Theos) made a joint statement on February 19, 2009 in support of the government's decision and condemning the activities of the Westboro Baptist Church saying, "We do not share [Westboro's] hatred of lesbian and gay people. We believe that God loves all, irrespective of sexual orientation, and we unreservedly stand against their message of hate toward those communities."[177][178]

Counter protests

Students kissing in front of protesters from Westboro Baptist Church at Oberlin College in Oberlin, Ohio. The students were among several hundred who turned out in May 2000 to rally against the Westboro protesters.

Counter protests are often organized to be held at sites that Westboro Baptist pickets.[44][70][179][180][181][182][183][184][185][186] In some cases, counter protesters have lined up and turned their backs on the Westboro Baptist pickets.

In 1999, inspired by the murder of Matthew Shepard the previous year, Michael Moore organized a protest against homophobia for his television show The Awful Truth. He toured states with anti-sodomy laws in the "Sodomobile", a pink bus filled with gay men and women. At one point, they visited the Westboro Church compound and got out to meet Fred Phelps, at which time Moore introduced the Sodomobile to him.[187][188][189]

Two days after the September 11 attacks in 2001, a 19-year-old man named Jared Dailey stood on the street corner facing the church holding up a plywood sign that said "Not today, Fred". Within two days, 86 people joined him, waving American flags and anti-hate signs.[190]

During a picket in Seaford, Delaware on May 21, 2006, one person broke through police lines and assaulted WBC members who fled into a police van. Five people faced criminal charges.[191]

Early in the morning of August 2, 2008, someone set fire to a garage near the Westboro Baptist Church, causing an estimated $10,000 in damages.[192][193]

On December 12, 2008, the group picketed a production of The Laramie Project at the Boston Center for the Arts. Local activists held a Phelps-A-Thon in response. Supporters pledged online to donate for every minute WBC protested. The event raised over $4,600 for an LGBT-rights project, Driving Equality.[194]

In March 2010, a Richmond, Virginia, ad-hoc group formed to create a counter protest to an planned Westboro Baptist Church visit protesting against Jewish and LGBT organizations. Pennies In Protest took pledges for each minute of the WBC protest. The funds (approx. $14,000) were then donated to those same Jewish and LGBT organizations that WBC was protesting.[195][196]

On November 30, 2010, disabled Army veteran Ryan Newell was arrested in his parked SUV outside the Wichita, Kansas, city hall while members of WBC were in a meeting inside. Guns and ammunition were found in the back of the SUV, and Newell was charged with weapons violations and felony conspiracy to commit aggravated battery. On June 23, 2011, Newell pleaded guilty to impersonating a law enforcement officer and was sentenced to two years of probation. Newell received public support for his actions, and fundraisers and websites were created by the public to help in his defense.[197][198]

On December 11, 2010, the day of the funeral of Elizabeth Edwards, a group called Line of Love planned to have about 200 protesters on the north side of West Edenton Street in Raleigh, North Carolina, while 10 Westboro members picketed on the south side of the street, two blocks away from the funeral. Westboro members who disagreed with Edwards' tolerance for gays were "promoting awareness of the dangers of homosexuality", Line of Love gave its goal as "promoting proper respect for funerals".[199]

On February 24, 2011, hacktivists successfully took Westboro Baptist Church's websites down. The church claims this was the work of Anonymous, but the group denied responsibility, instead identifying The Jester as the culprit.[200] During a live TV confrontation on The David Pakman Show between Shirley Phelps-Roper and Topiary of LulzSec, Phelps-Roper stated that Anonymous could not "stop God's message". In response, Topiary and an accomplice seized control of one of Westboro's subdomains during the confrontation.[201]

On September 16, 2011, when Westboro members picketed a Foo Fighters concert in Kansas City, Missouri, the band appeared on a truck float in front of the protesters. Dressed in homoerotic outfits, they performed their country-parody song "Keep It Clean" – which contained many homosexual references and overtones – from their "Hot Buns" viral video; midway though the song, lead singer Dave Grohl made a speech calling for equality and tolerance. The band uploaded a video of the impromptu performance the next day on their YouTube channel.[202]

After Westboro announced plans to picket funerals of victims of the Sandy Hook Elementary shooting on December 14, 2012, hacktivists from Anonymous executed a distributed denial of service attack (DDOS) on the Westboro's website, GodHatesFags.com, stating: "We will continuously DDOS until they are forced to put their inbred church tithes to use to pay for bandwidth."[203] Anonymous also simultaneously released a Westboro membership list, with the personal contact information for most Westboro members.[204]

On July 14, 2013, members of The Satanic Temple performed a "pink mass" ritual over the grave of Fred Phelps's mother. The group said that the "mass" would turn the dead woman into a posthumous lesbian.[205][206][207]

This group, the "Eastboro Baptist Church," was founded on November 25, 2014 as a Facebook group with the same name.[208]

A satirical Facebook page about God raised $80,000 from fans to post a billboard in Topeka that says "God Loves Gays", which debuted on September 8, 2014.[209]

On June 18, 2016, around 200 people blocked the view of picketing by members of the church that occurred after the 2016 Orlando nightclub shooting that resulted in 50 deaths at a nightclub frequented by members of the Orlando LGBT community.[70]

On July 2016, players of Pokémon Go turned the church into a "gym" led by a pink Clefairy named "Love is Love". Members of the church responded by branding the Pokémon a sodomite.[210][211]

Patriot Guard Riders

The Patriot Guard Riders is a motorcyclist group composed mostly of veterans who attend the funerals of members of the U.S. Armed Forces at the invitation of the deceased's family. The group was initially formed to shelter and protect the funerals from protesters from the WBC.[212]


Counter-protestor standing in front of WBC at Brown University in May 2009.

A slogan commonly invoked at the counter protests is "God hates figs".[213] Parodying the WBC all-capitals "God hates fags" signs, the counter-protest signs often invoke a passage in the Biblical book of Matthew to justify the claim about God and his feelings about figs. The signs have been noted at counter-protests at the University of Chicago;[214] in Spartanburg, South Carolina;[215] and in Portsmouth, New Hampshire,[216] as well as at the non-WBC-themed Rally to Restore Sanity.[217] The use of the signs has been invoked as a sign of sanity by the ACLU[218] and others.[217]

Documentation given out at various counter-protests cite biblical verses[219] in which Jesus says that none should eat the fruit of a fig tree (Mark 11:12–14), in which Jesus causes a fig tree to wither (Matthew 21:18–20), and in which God promises, as a punishment, to make someone like bad figs (Jeremiah 29:17). These are genuine citations, but are not the sole mentions of figs in the Bible.

Other sites and organizations have parodied the slogans of the Westboro Baptist Church, including God Hates Fred Phelps,[220] God Hates Bags,[221] and God Hates Shrimp.[222] The Cooper family in Kevin Smith's 2011 film Red State was reportedly inspired by the Westboro Baptist Church.[223]


A number of Phelps' critics have suggested that the actions of the Westboro Baptist Church are merely a ploy to receive attention and publicity above all else, though the Phelpses themselves deny this claim. Counter-protesting against the group, they suggest, gives them attention and incentive that they do not deserve; and a more effective response against Phelps would be to ignore his family and congregation completely.[224][225][226] WBC, through the closely related Phelps Chartered law firm, has collected fees under the Civil Rights Attorney's Fees Award Act of 1976 when their protests have been unlawfully disrupted.[227]

Katherine Weber of The Christian Post states that "Westboro is considered an extremist group by most mainstream Christian churches and secular groups, and is well known for its aggressive protesting style."[228] The Methodist Church, Baptist Church, Reformed Church, and Evangelical Church "have issued a joint statement repudiating the actions of Westboro Baptist Church,"[13] stating that:

We do not share their hatred of lesbian and gay people. We believe that God loves all, irrespective of sexual orientation, and we unreservedly stand against their message of hate toward those communities. Neither the style nor substance of their preaching expresses the historic, orthodox Christian faith. And we ask that the members of Westboro Baptist Church refrain from stirring up any more homophobic hatred in the UK or elsewhere.[13]

A frequent critic of the WBC is political commentator Bill O'Reilly, who regularly calls the church "evil and despicable".[229] Documentary filmmaker Michael Moore has also criticized the church.[230]

The Anti-Defamation League (ADL) describes the Westboro Baptist Church as "virulently homophobic", saying its anti-homosexual rhetoric is often a cover for anti-Semitism, anti-Americanism, racism, and anti-Catholicism.[231] The Southern Poverty Law Center (SPLC) has added the Westboro Baptist Church to its list of hate groups.[232][233][234] Jerry Falwell referred to Phelps as "a first-class nut".[235] WBC picketed Falwell's funeral service on May 22, 2007.[236]

In response to WBC's announcement that they would picket the vigil for victims of the December 14, 2012 Sandy Hook Elementary School shooting, several petitions to the White House (using the We the People system) have been submitted, calling on the President to legally recognize WBC as a hate group, revoke its tax exemption for religious organizations, and to ban protests at funerals and memorial services.[237] One petition, backed by the hacktivist group Anonymous, was submitted the day of the shootings, and reached more than 75,000 signatures within two days.[238]

Rapper Mac Lethal uploaded a video titled "Beatbox + iPhone + Guitar + Fast Rap = Win By Mac Lethal" on December 18, 2012 that took inspiration from the actions of the Westboro Baptist Church and the media after the Sandy Hook Elementary School shooting. Some of the lyrics include:[239][240][241]

And I might suck at guitar
but at least I've never protested a dead soldier's funeral,
and I might be losing my hair, but at least I've never judged a woman for thinking another woman is beautiful,
and sometimes, I mean sometimes,
I might even text message while I drive,
but I've never thanked God when a precious 5 year old child was shot, and died....

In 2013, Christian rock band Five Iron Frenzy recorded a song entitled "God Hates Flags" condemning the actions of the Westboro Baptist Church and similar organizations, including such lyrics as "If God is love you got it wrong waving all your placards and flags".[242]

Nathan Phelps, estranged son of Fred Phelps, claims he never had a relationship with his abusive father when he was growing up and that the Westboro Baptist Church is an organization for his father to "vent his rage and anger."[243] He alleges that, in addition to hurting others, his father used to physically abuse his wife and children by beating them with his fists and with the handle of a mattock to the point of bleeding.[243][244] Phelps' brother Mark has supported and repeated Nathan's claims of physical abuse by their father.[245] Since 2004, over 20 members of the church, mostly family members, have left the church and his family.[246]

In March 2014, Nathan posted on Facebook that his father was in a hospice in Topeka and was near death. Furthermore, Nathan also stated that he learned that Fred was excommunicated from the Westboro Baptist Church in August 2013, for reasons that are unclear.[247][248] These assertions were later reaffirmed by Mark Phelps.[249] Nathan has previously predicted the Westboro Baptist Church may fall into a leadership crisis and theological crisis when Fred dies, because he is the binding figure and because their beliefs hold that they are immortal, which will be disproved with the death of a member.[250] WBC spokesperson Steve Drain denied that Fred Sr. was on the verge of death and refused to confirm the reported excommunication.[251] Fred Sr. died three days later.

Mark Phelps left Westboro Baptist Church in 1973 and began "formal healing therapy in 1988 and worked toward healing and restoration, overcoming the horrible pain and fear from the 19 years of living with" his father. Mark Phelps, who was baptized in another local church in 1994, further states: "If I had to take my family to court and convict them of being followers of Christ, I am not sure where I would find the evidence."[252]

Lauren Drain, another former member of the Westboro Baptist Church, released an autobiography titled Banished in March 2013. She characterizes children, like herself, as being brainwashed into their belief system and describes consequences of questioning their belief system, such as her banishment.[253]

Documentary media coverage

In 2001, Sundance Channel aired the film A Union in Wait, a documentary about same-sex marriage directed by Ryan Butler. Phelps and members of Westboro Baptist Church appeared in the film after Phelps picketed Wake Forest Baptist Church at Wake Forest University over a proposed same-sex union ceremony.

In 2005, the British satellite company British Sky Broadcasting produced an investigative piece using hidden cameras, which included footage of two of Phelps' granddaughters, Libby and Jael.[254] In the testimonial, Libby and Jael explain that they hope and pray that no one outside of Westboro becomes "elect",[254] because they want everyone else in the world to die horribly and burn in Hell,[254] and that even if they did not believe their actions were dictated by God, they would still do and enjoy them anyway.[254] The interview was not part of the hidden camera segment, and although much of the footage was taken without the knowledge or permission of Westboro, the church maintains a link to the entire report on its website.

On April 1, 2007, the British television channel BBC Two broadcast Louis Theroux's The Most Hated Family in America.[255] Theroux has presented a number of documentaries about unusual or unconventional people and groups in the UK, the US and elsewhere.[256] A follow-up documentary by Theroux, America's Most Hated Family in Crisis, was broadcast in the UK on April 3, 2011. Theroux reported that Westboro was in a state of "crisis" and documented the departure of several young members.[257] Since then, two more prominent members have left the church.[258]

The website godhatesfags.com was prominently featured in The Jeremy Kyle Show, a talk show aired on the ITV network in the United Kingdom on June 5, 2007. Shirley Phelps-Roper and her daughters had been invited to express their beliefs live via satellite. On the show, Kyle criticized the Phelps for their beliefs and referred to the Phelps' children as "completely and utterly brainwashed", and to Phelps-Roper herself as "deranged".[259][260]

In the June 21, 2007, Channel 4 documentary Keith Allen Will Burn in Hell, starring Keith Allen, on which Phelps-Roper and some of her children agreed to appear, Phelps-Roper admitted on camera that her oldest son, Samuel, was born out of wedlock. Allen declared Phelps-Roper's vocal condemnation of strangers having sexual congress outside of marriage to be hypocritical as she was guilty of the same thing.[261]

In 2015, Sam Harris published an interview with Megan Phelps-Roper, granddaughter of Fred Phelps and former member of Westboro Baptist Church.


WBC's travel expenses exceed $200,000 annually.[262] According to the Southern Poverty Law Center, Westboro is funded entirely by its congregation and accepts no outside donations.[263] The church has received money from lawsuits and legal fees.[263][264] For example, they sued the city of Topeka several times in the 1990s.[263] WBC received $16,500, and is pursuing another $100,000, in legal fees for a case won in court.[264] The WBC is considered a nonprofit organization by the federal government, and is therefore exempt from paying taxes.[265]

According to the Louis Theroux documentary The Most Hated Family in America, members of the Phelps family are expected to have regular jobs and give ten percent of their earnings to the church, and many of them are lawyers.

Phelps Chartered Law Firm

Fred Phelps founded the Phelps Chartered Law Firm in 1964, which has since been used to sue communities that are targets of Westboro's protests.[266] All five of the law firm's attorneys are Phelps' children, and eleven of his thirteen children are lawyers.[267] Because the firm represents Westboro Baptist Church in its lawsuits, it can use money from cases it wins to further fund the church.[268] Though the firm is often successful, as observed by the SPLC, "One local lawyer, Pedro Irigonegaray, came up with a novel way to battle the Phelpses. When Phelps Chartered, alleging 'emotional damage,' sued someone who had filed a criminal complaint against a WBC member, Irigonegaray's team requested court approval to have a psychiatrist evaluate Phelps family members to determine the alleged damage. The Phelps firm settled without delay."[269]

See also


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