The shear volume of people who despised him -- so much so that even at his death they cannot say anything about him but nastiness.
 The response of Larry Flint toward the death of Rev. Falwell, which I site here:
The Reverend Jerry Falwell and I were arch enemies for fifteen years. We became involved in a lawsuit concerning First Amendment rights and Hustler magazine. Without question, this was my most important battle – the l988 Hustler Magazine, Inc., v. Jerry Falwell case, where after millions of dollars and much deliberation, the Supreme Court unanimously ruled in my favor.It's probably not so remarkable that Flynt took this opportunity to exemplify himself as a maker of history, but there is something extraordinary about this statement: somehow, Jerry Falwell was able to reach across the moral divide to the pornographer Larry Flynt.
My mother always told me that no matter how much you dislike a person, when you meet them face to face you will find characteristics about them that you like. Jerry Falwell was a perfect example of that. I hated everything he stood for, but after meeting him in person, years after the trial, Jerry Falwell and I became good friends. He would visit me in California and we would debate together on college campuses. I always appreciated his sincerity even though I knew what he was selling and he knew what I was selling.
The most important result of our relationship was the landmark decision from the Supreme Court that made parody protected speech, and the fact that much of what we see on television and hear on the radio today is a direct result of my having won that now famous case which Falwell played such an important role in.
There is a lesson there for those who are heaping hatred on Rev. Falwell: they are clearly wrong about who he was and what he was intending to do in this world. Megalomaniacs and demagogues don't make friends with people who hate everything they stand for. They don't imagine that there's a redemption for the "other side". But there is a lesson for the rest of us as well.
Listen: the viciousness with which some circles are saying "so long" to Rev. Falwell ought to be considered against the fact that Jerry Falwell spoke the truth -- insofar as he spoke it -- and also extended himself as an ambassador even to someone as diametrically-opposed to God's law as Larry Flynt.
This is a lesson in apologetics and evangelism, folks. Jerry Falwell was a flawed human person -- but guess what? So am I. And for the record: so are you. If, upon our deaths, there are none of the unsaved in the number who will say, "this one was my friend," perhaps we have wasted our time here.
Don't waste your life.