I wouldn't call it unqualified. The classic example, is you can't yell "fire" in a crowded theatre. But the Phelps crowd, so long as they remain within other laws, can say what they want. The same goes for the KKK, Jesse Jackson, Al Sharpton, and other racist hate-based groups.

Where Americans get mixed up is they think that right to free speech also means the right to whatever forum they want to express themselves in. That was the reaction when Cindy Sheehan got kicked out of the house chamber wearing a T-shirt.