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Anonymous (207.44.134.33)
06-23-2004, 06:05 PM
Gray Cary Ware & Freidenrich LLP
By Guylyn Cummins

America's tree-lined streets were once natural places for disseminating information and opinion, and for doing business. Lawsuits for defamation and invasion of privacy were few; dissemination of information was limited to the crowds that attended.
But America's "streets" today are broad and treeless. They transcend the continent, and have merged with foreign byways into an electronic fiberoptichighway linking millions. Information, opinion and defamatory falsehood are now heard 'round the world' the moment the missive is sent.
Other things have changed as well. While speech is still free in America, it is not cheap. To the contrary, it can be tremendously expensive unless it is painstakingly accurate (and provably so) or privileged. Even then, it may not be protected in countries where it is received which have no free speech protection.
Like so many other areas of our American life, it has become prudent for the risk adverse to practice safe speech -- especially on the Internet. Here is a quick road guide.


Rules of the Road for Safe Speech
Defamation is used to describe libel (written falsehoods) and slander (oral falsehoods).
What defamation is to individual reputation loss, trade libel or product disparagement is to product or business (economic) loss. These rules of the road generally apply to statements concerning both products and individuals or companies alike.


Questions You Should Ask Yourself
Most speech can be transmitted safely in America if you carefully answer the following questions before engaging your fingers.


Is what I am saying defamatory?
If defamatory, is it true and can I easily prove it?
Or does a privilege exist to protect myself from liability?

The answers to these three questions are the crux of protecting yourself against liability.


The Answers
Answer No. 1:
Defamation is a statement of fact, not opinion, which is false, unprivileged, and harms another's reputation by exposing him or her to hatred or ridicule, or which causes her or him to be shunned or avoided, or which has a tendency to injure him or her in occupation or business. Clear as mud?
In more graphic parlance, it includes such things as falsely accusing someone of a crime, professional misfeasance, incompetence or unfitness, a "loathsome" disease, or a serious moral transgression. For example, falsely attributing a "Scarlet A" to a minister is defamatory.

A statement of fact is one which is susceptible to objective proof, i.e., calling the Mayor "a felon." Since felonies are proscribed by law, the Mayor either has been convicted of a felony and is a felon, or has not and is not.

A statement of opinion is a subjective judgment, i.e., calling someone "mean-spirited" or a "rogue." Since opinion is protected speech, it is far better to accuse the Mayor of being "mean-spirited" and a "rogue" than a felon and a liar (although it doesn't make for as spicy journalism!).


Simply adding, "In my opinion the Mayor is a felon," will not get you off the hook. Statements of opinion are safe only so long as they do not imply facts which are false. Thus, it is okay to say, "In my opinion, the Mayor is a rogue"; however, it is not okay to add "and in my opinion, if the IRS were on its toes, he wouldn't be roaming the streets." The implied fact underlying the opinion which is not protected is an accusation of "tax evasion".


Answer No. 2:
A true statement is defensible and can not support liability for defamation. Truth will also deter most people from filing lawsuits against you.

However, for those few rebels who intend to teach you a lesson, the real issue is how expensive will it be to prove truth?


If the "truth" is a matter of public record (i.e., a felony conviction), you're home free and the lawsuit will be short lived. However, one of truth's major shortcomings is that it is variable. Rarely does anyone know what "the truth" is, but many people will loudly profess they do! Worse yet, try to convince a jury the statement is true after the plaintiff has taken numerous shots with his or her own witnesses at telling the jury all the reasons why it's false.


Answer No. 3:
If you can, try to wrap yourself in a privilege. Even bald-faced lies are protected if they are privileged.

Public Report Privilege: Fairly and accurately reporting public proceedings or official acts are privileged, even if the official loudly and falsely proclaims, "The Mayor is a drug addict!" Be accurate, though. Unfairly characterizing or inaccurately recounting what happened (i.e. "Joe Blow said the Major is an adulterer") is not privileged.


Fair Comment Privilege: This is a little like protected opinion. It is okay to say, "The Governor is mean-spirited"; but it is not okay to say, "The Governor has a brain tumor" if he does not. The key is to get the facts right! Your fair comment is then protected if it is fair. Fair comment is an especially important tool in consumer journalism, analysis of public officials and the like.


Constitutional Protection Privilege: This defense is better left to the lawyers as it involves analysis of "fault." In general, the rule is that if you pick on a public official or public figure, it is okay to be innocently wrong on your facts. However, you cannot be knowingly wrong or have serious doubts about truth or you're unprotected. If you are discussing a private figure, it is better to get the facts right.


The rationale for this privilege is that high-profile types necessarily expose themselves to public critique even before all of the true facts come to light (those politicians asked for the job of running this country, didn't they?). Thus, its alright to comment on the President's dishonesty in "Watergate" or perhaps "White Watergate" before all the facts are known, at least as long as you're not making the story up.


Just remember, it is far better to ask for permission (or for documentation of the true facts) than to ask for forgiveness -- especially when the missive you sent was received by millions.


False Light, Invasion of Privacy and Other Wrongs
False Light: "False light" is another theory of legal liability similar to defamation. The only real difference between the elements of false light and defamation is that the falsehood need not be defamatory to sustain liability, but need merely be false and cause offense to a person of reasonable sensibilities. Thus, "fictionalizing" or "shading" true facts in a false, offensive way may give rise to liability, despite the fact the facts are true and not defamatory.
Private Facts: Another theory of liability is "public disclosure of private facts." Under this theory, the information published is true, but will support liability if the fact was private (not publicly known), highly offensive to a person of ordinary sensibilities, and unnewsworthy or lacking "public interest" (i.e., no real reason the public needs to know). While it is alright to criticize your neighbor's product he has offered for sale in the marketplace, it is not okay while critiquing his product to lambast him for having AIDS, if that is not publicly known and newsworthy.

Wiretapping: It is not permissible to wiretap your enemy's telephone for information unless he consents. Stringent federal and state laws prohibit wiretapping. It is also not okay to trespass on your neighbors property unless he or she consents. It is okay, however, to overhear on the table of enemies next to you at a restaurant open to the public, as long as you do not plant a hidden microphone or other amplification device in their centerpiece.


Infliction of Emotional Distress: Variants of intentional or negligent "infliction of emotional distress" are also popular, but must clear all of the First Amendment hurdles for either defamation or privacy torts in order to be actionable. Thus, a plaintiff cannot plead around the First Amendment to silence your freedom of speech by alleging you caused him or her emotional distress.


Breach of Contract: Lastly, a new breach of contract tort has arisen for promising not to disclose information (i.e., a source or specific information), but then doing it. ("So Mrs. Gingrich, how does Newt really feel about Hillary, confidentially of course?") This falls into the category of don't make promises you can't or won't keep, or you may find yourself liable for breach of promise.


Correcting Errors
While the general rule is that a correction may reducedamages, it probably will not undo the harm caused by your falsehood or error. Moreover, it will establish that you made an error. Accordingly, before a retraction or correction is made, it is time to consult a lawyer.


Right to Remain Silent
The most important rule of speech when you're in trouble may well be found in your right to remain silent or the Fifth Amendment, rather than the First Amendment. That rule simply says, unless you are compelled by law to talk, you have the right to say nothing. When a lawsuit is threatened or pending, criminals and innocents alike would do well to follow this rule.


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This article is a publication of Gray Cary Ware & Freidenrich and should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general information purposes only, and you are urged to consult your own lawyer concerning your own situation and any specific legal questions you may have.
Torts/ Personal Injury False Light 6205

Anonymous (66.98.180.53)
06-23-2004, 06:26 PM
What is “defamation”?



Defamation is:

“The act of harming the reputation of another by making a false statement to a third person.” Blacks Law dictionary 927 (7th ed. 1999).



Elements of a defamation claim:



To create liability for defamation there must be:



a false and defamatory statement concerning another;

an unprivileged publication to a third party;

fault amounting to negligence on the part of the publisher and;

either actionability of the statement irrespective of special harm or the existence of special harm caused by the publication. RESTATEMENT (SECOND) OF TORTS § 558.



A communication is defamatory if it:

“[T]ends so to harm the reputation of another as to lower him in the estimation of the community or to deter third persons from associating or dealing with him.” Restatement (Second) of torts § 559 (1977).



Defamation may take two forms: a defamatory oral communication is “slander” while a defamatory written communication is “libel.” Blacks Law Dictionary 927 (7th ed. 1999).

Anonymous (66.98.180.53)
06-23-2004, 06:27 PM
Although the First Amendment protects our freedom of speech as a fundamental right, it is not an absolute right. The U.S. Supreme Court has identified defamation as an exception to the fundamental right of freedom of speech, meaning states may regulate or prohibit defamation. N.Y. Times Co. v. Sullivan, 376 U.S. 254, 268-72 (1964). (“Whatever is added to the world of libel is taken from the world of free debate.”). Additionally, defamation is classified as a tort, and state law regulates it. Id.



There is no master list of defamatory words. Instead, each case is a fact-heavy, totality of the circumstances determination of whether the statement was false and understood as defamatory by its audience. Babb v. Minder, 806 F.2d 749, 758 (7th Cir. 1986). How the communication is understood, however, is not a completely subjective question. Whether a statement is capable of being defamatory is a question of law, rather than fact, and a court will only apply reasonable meanings to statements. Restatement (Second) of Torts § 563 (1977).

Anonymous (66.98.180.53)
06-23-2004, 06:28 PM
Defenses to Defamation:


There are two defenses to defamation that change the standard applied to the case. The general standard applied to defamation cases is negligence. However, if the defendant can show that the “target” of the defamation was a public figure or matter of public concern or that the defendant was only voicing an opinion rather than stating facts, then the plaintiff will have to show actual malice by the defendant to be successful in a defamation suit. N.Y. Times Co. v. Sullivan, 376 U.S. 254, 268-72 (1964). Mere negligence does not suffice to meet this standard, rather, the plaintiff must prove that the author “in fact entertained serious doubts as to the truth of the publication,” yet published it regardless or because of this fact. St. Amant v. Thompson, 390 U.S. 727, 731 (1968). As the U.S. Supreme Court explained this public figure exception:

Anonymous (66.98.180.53)
06-23-2004, 06:28 PM
“[If] the plaintiff is a public figure, he cannot recover unless he proves by clear and convincing evidence that the defendant published the defamatory statement with actual malice, i.e., with ‘knowledge that it was false or with reckless disregard of whether it was false or not’.” Masson v. The New Yorker Magazine, 501 U.S. 496, 510 (1991).

Anonymous (207.44.134.33)
06-23-2004, 06:29 PM
Damages in Defamation Actions




Defamation plaintiffs may seek three types of damages: general, special, and punitive. General, or “presumed” damages, are a form of compensatory damage given to compensate the plaintiff for harm to his/her/its reputation due to the defamatory publication.

Special damages are given if something with economic or pecuniary value is harmed, which in the case of defamation, “must flow directly from the injury to reputation cause by the defamation.” Special damages must be pled with specificity in slander actions.

Anonymous (66.98.180.53)
06-23-2004, 06:30 PM
Punitive damages, which are intended to punish, are awarded only if the plaintiff proves actual malice on the part of the defendant in writing or publishing the defamatory material. If the alleged wrongdoing is based on negligence, then damages are limited to “actual injury”. If the defendant was merely negligent, a court cannot constitutionally award punitive damages. See Gertz v. Robert Welch, Jr., 418 U.S. 323, 94 S.Ct. 2997(1974).

Anonymous (66.98.180.53)
06-23-2004, 06:30 PM
If the plaintiff pleads libel or slander per se (such that any reasonable person must find the statement defamatory), then the plaintiff does not need to show damages. Otherwise, damages are an element of any defamation claim.

Rest. § 621 states:

“One who is liable for a defamatory communication is liable for the proved, actual harm caused to the reputation of the person defamed.”

Rest. § 569 states:

“One who falsely published matter defamatory of another in such a manner as to make the publication a libel is subject to liability to the other although no special harm results from the publication.”

For more on the damages available in defamation actions, see Michael Hadley, The Gertz Doctrine and Internet Defamation, 84 Va. L. Rev. 477, 480-81 (1998).

Anonymous (66.98.180.53)
06-23-2004, 06:31 PM
SLAPP Suits


Strategic Lawsuits Against Public Participation (or SLAPP’s as they are commonly called), are civil complaints in which the allegedly wrongful behavior is activity protected by the First Amendment, such as a petition. Defamation is one tort that is typically the basis of a SLAPP suit, other claims include conspiracy and interference with an economic interest. Usually, plaintiffs file SLAPP suits not hoping to win a damage award, but merely to stop the discussion on an issue. For the above reason, states have introduced Anti-SLAPP legislation to terminate these lawsuits and also the harassment they create for innocent defendants. At least twenty states have enacted Anti-SLAPP laws, and these laws range in what areas are covered as well as whether the court must even consider the strength or legitimacy of the plaintiffs case. Additionally, the U.S. Supreme Court has dealt with lawsuits that are characterized as SLAPPs, but the Court has never referred to them as such.

Anonymous (207.44.134.33)
06-23-2004, 06:32 PM
An example of Anti-SLAPP legislation is California’s Code of Civil Procedure § 425.16, which “provides for a special motion to strike a complaint where the complaint arises from conduct that falls within the rights of petition and free speech,” and allows a prevailing defendant to recover any costs he/she encounters while defending such litigation.

States that have enacted Anti-SLAPP litigation receive cases from the wronged defendants seeking either to strike the underlying lawsuit at the pleading stages or attorney’s fees. As a California Court of Appeals explained how the SLAPP statutes apply to a slander case:

Anonymous (207.44.134.33)
06-23-2004, 06:32 PM
Averill publicly criticized a plan by a charitable organization to convert a house in her neighborhood into a shelter for battered women. After she attempted to persuade her employer not to contribute to the charity, the charity sued her for slander solely for her comments to her employer. The lower court's denial of Averill's special motion to strike the complaint is reversed. The appellate court holds that comments made in private, if made in connection with a public issue, are protected by the anti-SLAPP statute.” Averill v. The Superior Home, Inc., 50 Cal.Rptr.2d 62 (Cal. App. 4th 1996).

Anonymous (207.44.134.33)
06-23-2004, 06:33 PM
Defendants in California will only be successful, however, if their case falls within the state SLAPP guidelines.

“Plaintiff sued defendants for multiple causes, including defamation, based on ‘negative statements’ about the company on an internet forum for discussion of large, publicly traded corporations. Defendant Woods, who had posted the remarks, filed a special motion to strike the complaint against him under the California anti-SLAPP statute. The court denies the motion on the grounds that the remarks did not concern a public issue and therefore are not protected by the statute.” MCSI, Inc. v. Woods et al. ___F. Supp.2d ___ (N.D. Cal. 2003).



Suits of this type that are based on Internet activities are dubbed cyberslapp suits. See Russell Thomas Hickey, "A Call for Protection: Applying existing Anti-SLAPP statutes to the Internet" (2000). The same Anti-SLAPP laws will apply to online communications as well as more traditional forms.

Anonymous (66.98.180.53)
06-23-2004, 06:44 PM
More Later:
http://www.factnet.org/discus/clipart/happy.gif

Anonymous (151.196.137.80)
07-26-2004, 01:27 PM
Food for thought for today 7/26/04

Anonymous (68.82.183.197)
08-10-2004, 03:56 AM
do something Satan doesn't want you to do tonight....PRAY

Anonymous (68.82.183.197)
08-10-2004, 03:56 AM
do something Satan doesn't want you to do tonight....PRAY

Anonymous (141.154.144.33)
08-10-2004, 03:57 AM
Anon 68...do something we want you to do....stop screwing up the board and go pray