From _The First Amendment Book_ by Robert J. Wagmam, p. 157:

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The Supreme Court's most ringing recent defense of freedom of the
press came in 1988 (_Hustler Magazine v. Falwell_) when the Rev. Jerry
Falwell tried to recover damages from _Hustler, charging the magazine
and its publisher, Larry Flynt, with "intentional infliction of
emotional injury." Falwell said he suffered emotional trauma after
reading a vicious cartoon parody about himself in the sex magazine.
The cartoon implied that Falwell had had sex with his mother in an
outhouse. Effectively, what Falwell tried was an end run about libel
law. He was clearly a public figure, and rather than have to
prove{actual malice and loss of reputation (the parody was so
ridiculous and extreme that no sane person could have believe it, and
thus there was not lose of reputation), Falwell sought to prove that
there had been an intentional infliction of emotional distress on the
part of _Hustler and to try to collect on that tort basis. But the
Court struck down the attempt. Chief Justice Rehnquist wrote that "in
public debate our own citizens must tolerate insulting, and even
outrageous speech in order to provide adequate breathing space to the
freedoms protected by the First Amendment."

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