Calling the deputy a "fat slob...[who] broke all the zoning rules" is not grounds for arrest
Kenneth Kennedy became involved in a zoning dispute with Joseph Schutzman, a City Police Officer and building inspector. After Schutzman refused to speak with Kennedy at the city building, Kennedy told nearby city workers that Schutzman was a "fat slob" and that "the son of a bitch broke all of the zoning laws." Schutzman responded by arresting Kennedy, even though he was not unreasonably loud and did not threaten to generate public alarm.
After Kennedy was found not guilty of disturbing the peace, he sued Schutzman and the Sixth Circuit upheld his right to bring a Fourth Amendment illegal seizure claim. A factfinder could readily find that Schutzman was motivated by personal insults to arrest Kennedy: if it does, the arrest would be a violation of Kennedy's civil rights under the Constitution.