So… it’s not just me who feels uneasy about aspects of the recently-released blogger restraint & gagging order I discussed in my post ‘Is this what we want? Internet ‘take down’ and indefinite gagging orders?‘.
Steven Price is a media lawyer, a law lecturer at my alma mater Victoria University of Wellington, and a legal thinker whose blog medialawjournal.co.nz I read now and then. He’s smart.
In an article just published at the Inforrm (International Forum for Responsible Media) Blog, with this scary title: ‘Has the Harassment Act just swallowed the law of defamation?‘ he shares his ‘take’ on Judge David Harvey’s Decision.
Steven Price’s article calls it ‘a radical judgement that bypasses defamation law’ and the restraint order ‘a whopper’ before concluding (as I do) that the take-down order would probably also be granted under the Law Commission’s proposed cyber-bullying regime. Fair enough.
But when I spoke to him about it briefly this afternoon, I think it’s fair to say neither of us felt so sure about the indefinite and very broad gagging order. To me, as I said, and as Jay said here and following, that feels like a step too far. (Tip of the day: Never try to get legal advice from a law lecturer.)
… At least one judge has held that this requires an examination of the law of defamation to see whether a defence of truth or honest opinion might be available, and warned that harassment law should not be used to undermine the high threshold for an injunction in defamation cases: B v Reardon [2000].
As noted, Sperling (pic) didn’t advance any defence. But I couldn’t help but notice the plethora of issues that this case would have raised in a defamation context.
Hmmm, I thought, some of those statements look like they might be protected by honest opinion.
And: I’m not sure there’s a clear defamatory meaning for one or two others.
And: isn’t there a case that one or two of those allegations might attract a qualified privilege defence?
And: should we be troubled by the fact that the judge doesn’t have to make a finding that these harassing smears are untrue?Judge Harvey knows the New Zealand Bill of Rights needs to be factored in. He assures us he has:
“Weighed each post and considered whether, in terms of content and the competing interests of the parties, the removal of the post would amount to a justifiable limitation upon Ms Sperling’s free expression rights.”
But he gives us little sense of how that justification process was conducted, except in his analysis of the appropriate duration of his take-down order.
And that take-down order is a whopper: not only does it order Sperling to remove dozens of posts unless and until the court permits reinstatement, it also forbids her from directly or indirectly mentioning Flannagan or her family online.
That seems to prevent her from discussing Judge Harvey’s decision, for example.
This is a long way from the courts’ great reluctance to grant injunctions affecting free speech in most other contexts.
But there is something to be said for that. The law of defamation is byzantine. It would not offer most people an easy remedy here.
There’s much evidence that Sperling’s posts were malicious and harmful, and they are now banned. …
Read Steven Price’s thoughtful article in full at The Inforrm Blog.
– P
He’s from your old Alma Mater and (according to you) he’s smart … and you read his journal. You didnt play for Notre Dame as quarterback perchance.
And do you both belong to skull and bones and do you have secret handshakes and hopefully clean the secret goatshit off the carpet afterward.
On a less frivolous and jocular note .. its heartening to see that others are seeing the seriousness of the case at hand …
Hey Ivan, I think you left your hemp robe, a half-burnt mugwort smudge stick and a goat-skull (is that yours?) behind the altar at the hall after our last initiation …
i did mate … the smudge stick didnt smoulder and smelt like a badly set up pad-burner at a high school reunion …
But hey – no ritual undertaking ever goes to plan …..
You would never see me dead or otherwise in a hemp robe (cheeky bitch) in a hemp robe (listening to graeme again i see …) and mugwort is so f####ing yesterdays news mate …
Hi Peter,
I note Steven Price’s comment that, “[Ms Sperling] can still raise her concerns in other fora.” This brings to mind some of your questions on your previous post on this issue – what if Ms Sperling were to be the subject of an in depth newspaper interview about Ms Flannagan; or what if she or someone else were to write a book about the whole shermozzle? (excuse my paraphrasing.)
There certainly is a curious disconnect between the judgment’s treatment of different technologies used for the dissemination of ideas – Ms Sperling is banned from even mentioning Ms Flannagan online, let alone discussing the judgment, yet if she were given (for example) a spot in the NZ Herald as a columnist and vented her spleen about the judgment for all the world to see she would presumably not be in breach of the Restraining Order…
So… what happens then, should the NZ Herald place her column online? Presumably nothing, as the NZ Herald website is not a forum that Ms Sperling has any control over. And there’s nothing stopping Ms Sperling writing what she likes about Ms Flannagan in a context that isn’t online, so long as the content wouldn’t ordinarily be considered a specified act for the purposes of the Harassment Act.
Of course, it’s somewhat unlikely that the NZ Herald will be inviting Ms Sperling to display her journalistic talents any time soon. But what about if Ms Sperling were to write an email (or a typewritten letter, if we’re going to be really safe and remove her from a computer altogether throughout this process…) to a blogger, which the blogger then posts online? Surely, as long as there’s plausible deniability that it was going to be posted (“Honestly, officer, it was just an email to a friend/acquaintance… How could I have possibly known that (s)he’d post it?!?”), there’d be no offence?
Although it’s a good thing that Parliament has turned its attention to the issue of online harassment, with the new cyber-bullying regime, it would appear that our politicians should perhaps consider a revamp of both defamation law and the Harassment Act at the same time, as I’m not sure the current law is really up to the job of factoring in technological nuances… Mind you, I’d hate to be the one having to write any revamped law!
Hi Jay,
Thanks for your thoughts. Yes, it’s partly unexplored territory, isn’t it?
Another factor, which is one of the issues I asked Steven Price about, is how ‘frontline’ police might respond to a complaint of the sort you predicted would be laid against the blogger’s (since-deleted) innocuous “So I have been in hospital” post.
That question raises more of my civil rights concerns, as, it seems to me, the police-on-the-beat/patrol are used to dealing fairly ‘blanket’ restraining orders. Subtleties may be lost.
As you say: What if, hypothetically, the blogger was to author a lengthy first person account of the whole dispute (from her side), attaching whatever evidence she had to support her claims as ‘true’, naming the parties outright, taking issue with Judge Harvey’s characterisation of her and her motivations in his Decision …
… and then seek a publisher for it‚ or even submit it to a ‘sympathetic’ fellow blogger to put online where she, although being the author, didn’t have ‘moderation’ power? (See how messy this is getting?)
Such an article/book/publication wouldn’t necessarily defame anybody (see Steven Price’s thoughts on defences, thresholds for injunctions etc) but, as you say, if it found itself online, it could be regarded as part of the ‘pattern’ of harassing behaviour. (And nobody, least of all me, wants to see that harassment continue, for either party.)
But (bigger but) isn’t it the blogger’s right to do that?
And THEN, what if someone laid a police complaint alleging writing and publishing that account was a breach of the restraining order. Will your typical local Howick bobby, or the sergeant, be receptive the finer points of ‘which she can moderate’ (para [76] of the Order).
Or will a police car just pull up outside her house, as you suggest, or police officers cart her off as having breached the order?
Asking for a friend. 🙂
Hi Peter,
Unexplored territory? Yes, indeed! Which is fascinating for an armchair viewer like myself with no particular iron in the fire, but perhaps less fascinating for Ms Sperling (given the many unanswered questions regarding what she can and cannot do online, and the fact that the only way she can get answers is to chance her arm and wait to see whether the Police show up…)
You ask – “But (bigger but) isn’t it the blogger’s right to do that?”
Precisely.
You and I have the freedom to debate the issues raised by Judge Harvey’s judgment, by posting and commenting online. We can consider the legal ins and outs of the judgment, the different elements of the legal test applied by His Honour and the conclusions he drew, whether the evidence alluded to by His Honour satisfies said legal tests, what the broader implications of the judgment are to the wider internet community, and of course what actions are likely to actually result in a prosecution for a breach of the Restraining Order in this particular case.
Ms Sperling is severely limited in terms of such freedoms (or should I say, if I were in her shoes I would not be intending to push the issue of whether those freedoms currently exist for her…).
And yet, those freedoms appear to be curtailed only in an online context. If her opinions on Ms Flannagan were to appear in the old-fashioned print media (and were not obviously defamatory), I fail to see how she could fall foul of the Restraining Order.
From there, anyone is free to scan a copy of that piece of print, and post it online. As you point out, for the purposes of whether Ms Sperling is in breach of the Restraining Order, ‘moderation’ power is key. If Ms Sperling has not posted online, and has no ‘moderation’ power over the forum in which her views (previously existing only in physical, not online, form) have appeared, how can there have been any breach of the Restraining Order (assuming that the contents of any print media article, whether written by her or by someone else, would not constitute an offence under the standard conditions of the Restraining Order – the ‘take down’ and ‘gagging’ orders of course being special conditions of the Order).
But of course I’m assuming that a Court would follow my interpretation of the law – and as you know, I didn’t think that a Judge would find that enough had changed to warrant a change in stance with regards to the objective test for distress as applied to Ms Flannagan, so I wouldn’t necessarily trust my interpretation!
To the nitty gritty of your last couple of paragraphs? My experience with the Police is that individual officers won’t put their asses on the line when it comes to arresting people for possible technical breaches of the law. If they don’t understand the situation, your average bobby/sergeant will generally keep going up the Police food chain, seeking advice as to whether: a) any law has in fact been broken; and b) if so, whether it’s in the public interest to in fact lay a charge (after all, Police have to make pragmatic decisions when it comes to dragging people through the Courts and they don’t have an unlimited budget – in fact, as far as I’m aware, the prosecution guidelines require Police to consider factors such as public interest and use of public funds before laying a charge).
That means that if a police complaint were laid regarding the scenario you set out, it’s likely that initial inquiries would be made (i.e. Police car pulling up outside her house), with advice then being sought from the higher echelons before any decision was made to cart anyone down to the station…
But I don’t think that Police would lay a charge, as they’d struggle to satisfy the elements of the charge (both the actus reus – she wouldn’t have actually published anything online herself – and the mens rea – it would be somewhat difficult to prove that she’d intended for anything to be published online…).
Thank you Jay.
I must say, I really appreciate your willingness to share your perspective of these important (but so multi-layered!) issues.
Good on you. – P
I am not sure if you guys will find this interesting but the post below concerns what I think are similar situations which have arisen in England and Wales recently and I thought relevant to the article on Inforrm blog. I attempted to post it there (several times as well as other posts) without success as it had more relevance to UK readers but perhaps it might be of interest here. It mentions the UK ‘Solicitors from Hell’ case where the website owner had his site shut down using harassment law. Also another person I know had a website which made largely truthful posts about solicitors and consumer affairs and was closed down in a similar fashion.
Unfortunately it seems censorship in the UK is alive and well because Inforrm blog do not seem to publish useful observations on the law unless it conforms to the views of the legally minded people who appear to run and write articles for the site. I hope it makes sense anyway.
My unpublished post on Inforrm Blog:
……………
“Why sue for defamation when you can get an injunction by showing that a publisher has harassed and distressed you instead”?
Interesting that this subject has been raised only now because for a while I have been highlighting a disturbing trend in cases in England and Wales. I also commented on a previous Inforrm article about Law Society V Kordowski many months back and raised these concerns.
This is what the judge said about the listings of solicitors on the well known website ‘Solicitors from Hell’ – which was closed down. Some of the solicitors took action to remove comments about them. In my opinion most comments had some truth in them but obviously some of the listings were inaccurate or unfair.
“There is no need for evidence of falsity for me to reach this conclusion. Even if there were evidence that the allegations were true, the conduct of the Defendant could still not even arguably be brought within any of the defences recognised by the PHA. No individual is entitled to impose on any other person an unlimited punishment by gross humiliation such as the Defendant has done, and claims the right to do. His conduct is a gross interference with the rights of the individuals he names.’ [133]”
At the time I questioned whether the judge was giving the green light for libel litigants to sue bloggers and journalists who had researched and published stories in the public interest. If we follow the judges guidance, in theory virtually anyone commenting on matters of public interest and naming an individual could be sued for harassment instead of libel. Far easier because there is no defence of truthful and honest comment. So I questioned for example, whether the guidance was a licence for wrongdoers to curb free speech and discourage investigation of their activities. For example given this guidance would a judge following an allegation of harassment stop BBC Watchdog’ from its activities and showing its ‘Rogues Gallery’? At least something for readers to think about here.
In reality, judges may only reach similar decisions in more extreme cases. That said, it does raise concerns over decision making and consistency of the judiciary. Judge Tugendhat seems to be making quite a name for himself in the arbitrary way he has dealt with many recent libel/harassment cases. (Law Society V Kowdowski, Waterson V Lloyd and McAlpine V Bercow) The contradictions when reading many of his judgements is quite obvious and in some cases, wrong in law.
……………..
That was a very interesting read Loverat. Thanks for sharing.
There has to be a bell-shaped curve for lawyers as there is for bloggers and journalists and judges (gasp).
Some must be very good, some must be very bad, and most must be average.
– P
More like a ‘bulge-shaped’ curve for lawyers … charging regimes … flatfish and such ….
Peter
There are some excellent libel lawyers and barristers in the UK but very few in mumbers imo. Most of them I have to say are hopeless but they get by because anything to do with defamation scares the hell out of the public and one non compliant letter full of holes is normally enough to bully someone into submission.
I am not legally trained but under the old much criticised libel law I could run rings around most. But the stuff mentioned above does worry me. At least before, the playing field was more level and you could at least fight and probably eventually win.
Nowadays it seems anyone can be gagged, their site shut down in 5 minutes on the say so of a lawyer or a judge who is against you from the start. This seems to be a direct result of a temporary improvement in the numbers of libel defendants winning their cases. 81% in 2010 and libel claims started to become much more difficult to pursue after a spate of publicity about abusive libel cases.
I have researched alot of decisions in very recent libel cases and I can definitely see another shift and detect many clear contradictions in outcomes. It seems judges are able to interpret and apply the law to the outcome they desire without these contradictions being obviously detectable.
For example the McAlpine V Bercow case if you have been following it is interesting. The judge delivered a decision on meaning which when read did not sound wrong. However, by not hearing any submissions on the wider context, abuse of process or over-compensation of the claimant from other defendants, the outcome reached was totally wrong. The judge must have simply chosen to ignore this because I suspect there is no way the claimant would have otherwise received any further settlement offer from Bercow.
Lawyers do not seem to notice the errors or at least wish to criticise them. That is one of many reasons why lawyers in the UK are generally disliked.
[…] Here’s NZConservative blogger Lucia Maria, replying to [public] correspondence with the successful applicant in the recent internet take-down and gagging order case I referred to in Is this what we want? Internet ‘take down’ and indefinite gagging orders? and Steven Price: ‘wider factors to consider’ in recent online gagging order. […]