It's not uncommon for people to mix up epitaph, epithet, epigraph, and epigram; I've seen a brief, for instance, which spoke of "personally abusive epitaphs."

The Seventh Circuit, though, has just handed down an opinion which did indeed involve personally abusive epitaphs (though only mock epitaphs). More importantly, the opinion is a pretty interesting elaboration of First Amendment fighting words doctrine, and quite readable, to boot.

Thanks to How Appealing for the pointer.