For the cultists yelling "fire" in a crowded movie theater? Er.. "fa**ot" and "war criminal" at the funeral of a stateside murdered marine?
You cannot slander the dead but there is still provocation by levying false charges against the dead. It is an outrageous act.
Abortion foes cannot stand outside an abortuary and protest. It interrupts the business of abortion. This funeral protest is likewise bad for the funeral business.