14 honorary members of the department after completing puzzles and quizzes; that the department had discov- ered an experimental technique for abortions and would be providing them to teens for free in a police van; that the department was soliciting job applicants but that minorities were “strongly encourag[ed]” not to apply; and that the department was banning city resi- dents from feeding homeless people in “an attempt to have the homeless population eventually leave our City due to starvation.” Pet. App. 139a–41a. True; not all humor is equally transcendent. But the quality and taste of the parody is irrelevant. See Hustler, 485 U.S. at 55; Pring v. Penthouse Int’l, Ltd., 695 F.2d 438, 443 (10th Cir. 1982) (extending First Amendment protections to a parody that had “no re- deeming features whatever”). And there is no real doubt that reasonable readers would have no diffi- culty in ascertaining that Parma’s finest were not ac- tually providing free abortions to teens in a police van, pardoning child sex offenders on the basis of their adeptness at puzzles, or intentionally starving the homeless. The absence of a disclaimer lends nothing to the analysis. Under a proper understanding of the reasonable- reader test, a disclaimer not only spoils the punchline but is redundant. The Sixth Circuit’s holding stands alone among the otherwise uniform approach courts have taken—and not in a good way.
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