"Fighting words" are not protected.
And if going to a funeral and saying that you are glad that someone's beloved son is dead is NOT an example of fighhting words, it's hard to know what is.
Exactly. At some point, a wise police department should tell Phelps' gang, at the outset, that they are engaged in incitement to riot, give them the alloted time to disperse, and then arrest them after they refuse to disperse.