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Cairns v Modi judgment

March 27, 2012

Is here.

Topics: General | Comments Off on Cairns v Modi judgment

Doesn’t sound like a fair go to me

March 1, 2012

So the head of TVOne and Two, Jeff Latch, asks for a powwow with Fair Go staff. Labour broadcasting spokesperson Clare Curran asks whether, at that meeting, he asked them to go easy on TVNZ’s advertisers. Here’s his response:

“The key points I made at that meeting was that the heart of Fair Go for the past 20 odd years it has been on television, is that it represents the underdog and the small guy and stands up for them,” he told Parliament’s commerce select committee.

“I also made the observation we operate in a commercial environment and Fair Go, like all our programmes, need to exercise care in the way they handle stories.”

Journalists needed to make sure stories were always balanced with the views of both sides of the story, he said.

“A story that is not balanced could be something that is not really what we would want to run on that network.”

Latch said there was “nodding acceptance around the room that that made sense”.

It does make sense. So much sense, in fact, that you have to wonder why Jeff Latch had to organise a meeting with Fair Go to tell them that. Did he also mention that they should try to be accurate? Not defame people? Latch should know that Fair Go are probably the TVNZ reporters best versed in broadcasting standards and media law, since they deal with them every week. (Back in my days at Kensington Swan, I used to provide advice to them).

Asked if he was instructing Fair Go not to produce programmes that upset advertisers, he said “it wasn’t an instruction, per se.”

Not per se? This sounds weasily to me. Was it a hint, Mr Latch?

Because actually, Fair Go has a pretty good track record in its broadcasting standards complaints. It has not been listed in the BSA’s “Most complained about” shows for at least the past three years, despite the fact that it often makes serious accusations against people with the resources to sue. Likewise, there haven’t been any reported defamation cases against them in the last few years, as far as I can tell. Was there a big secret settlement recently?

If not, Mr Latch – how should I put this? – you should stay the fuck away from the Fair Go staff. It’s their job to tackle TVNZ’s advertisers when that is merited, and it’s your job to hire good journos then leave them to get on with their job.

Topics: Media ethics | Comments Off on Doesn’t sound like a fair go to me

Should we have a tort of intrusion?

February 28, 2012

How far does our privacy tort stretch? Does it – should it – include offensive intrusions into someone’s affairs?

It is well established now that you can sue for invasion of privacy if someone offensively publishes sensitive private facts about you and there’s no redeeming public interest. A newspaper reveals you had an abortion as a teenager. A blogger publishes pictures of you naked. Someone tweets that you have an STD. The tort of invasion of privacy, at least in theory, could provide you with an injunction or damages for these revelations. But what if there’s no publication? What if someone reads your diary, eavesdrops on your intimate conversation, improperly accesses your health or bank records, films you with a hidden camera, or sneaks a peek at your video rental history? Depending on the circumstances, you might be able to avail yourself of one of a range of legal remedies such as harassment, breach of confidence, nuisance, trespass, or the offences of intimat

e covert filming or illegal interception. The Privacy Act may provide protection: you can complain, for instance, if material about you has been gathered in a way that is unfair, unlawful or unreasonably intrusive, and you can show that you’ve suffered harm as a result.

But these avenues all have limitations, and won’t necessarily provide for an injunction or damages. The Privacy Act does not apply to newsgathering journalists.

Might the tort of invasion of privacy be stretched to include this sort of intrusion, even without publication – in fact, even if the intrusive behaviour doesn’t turn up any truly private facts? Might the tort recognise that the harm here is the offensive prying into a person’s interests in seclusion?

Yes it might. New Zealand’s leading privacy case, Hosking v Runting [2005] 1 NZLR 1, deliberately leaves this question open. “We need not decide at this time whether a tortious remedy should be available in New Zealand for unreasonable intrusion into a person’s solitude or seclusion,” say Gault P and Blanchard J. “The cause of action will evolve through future decisions as Courts assess the nature and impact of particular circumstances.”

Last month, the Court of Appeal for Ontario took this step. In Jones v Tsige (2012 ONCA 32), the judges developed the law to award $10,000 in damages against a bank employee who accessed a colleague’s bank records 174 times over four years. “Recognition of [a right to sue for intrusion upon seclusion] would amount to an incremental step that is consistent with the role of this court to develop the common law in a manner consistent with the changing needs of society,” wrote Sharpe JA for the court, citing supportive case law from Canada and elsewhere, the growing problems caused by intrusive technology, and increasing academic support for the change. The court suggested that damages should be modest and free expression rights borne in mind where relevant.

Now, if these facts were to arise in New Zealand, I’d expect the Privacy Commissioner’s office to be the first stop. It seems that the equivalent Canadian privacy legislation has more limited reach. But I also expect that our courts will be likely to follow the Court of Appeal for Ontario in expanding our tort. I say this for four main reasons.

First, this development is in line with the underlying reasons for protecting privacy: allowing us space to develop intimacy, trust, and creativeness away from the gaze of others; acknowledging our dignity; giving us control over what we allow others to see of us; and giving us room to relax, experiment and let off steam.

Second, American law already contains this strand of privacy violation. It has been picked up by our Broadcasting Standards Authority, which provides a remedy against offensive intrusions – by hidden camera, for example  –  where there’s no sufficient public interest to justify the invasiveness. The BSA has shown this remedy to be workable and flexible. (Admittedly the BSA complaints only arise in the context of complaints against material that has been published. But the BSA is not asking whether the broadcast itself was intrusive or offensive, but whether the prying that led to the broadcast was intrusive). The intrusion remedy contains many familiar elements: reasonable expectations of privacy as a touchstone, highly offensive intrusions, defences of consent and public interest. The High Court has approved this development. Cases have shown the need for it: see for example, O’Connell v TVWorks 2007-067, where Target broadcast hidden camera footage of caregivers, even though most of those caught on film were doing little that was really wrong. It doesn’t make much sense for there to be an intrusion remedy for complaints against broadcasters, but not against anyone else.

Third, this new strand of privacy violation imposes less on freedom of expression, since it does not revolve around publication. It may constrain the gathering of information, however, so the resulting restriction on free speech arguably needs to be demonstrably justified under the New Zealand Bill of Rights Act. Properly applied, I think it can be justified. The threshold of offensiveness is a high one. The public interest defence protects significant speech. The requirement of proportionality should ensure that the tort is kept in its place.

Fourth, the Ontario Court of Appeal is surely right that galloping technology is vastly expanding the opportunities for intrusions on our private affairs. The tools for invasive covert recording are often no further away than our pocket or purse, and there’s a growing willingness to use them. I’ll leave the last words to the authors of the most famous legal article in history: Samuel Warren and Louis Brandeis, arguing that the common law should recognise a tort of invasion of privacy – back in 1890.

The intensity and complexity of life, attendant upon advancing civilisation, have rendered necessary some retreat from the world, and man, under the refining influence of culture, has become more sensitive to publicity, so that solitude and privacy have become more essential to the individual; but modern enterprise and invention have, through invasions upon his privacy, subjected him to mental pain and distress far greater than could be inflicted by mere bodily injury.

(“The Right to Privacy”, 4 (5) Harvard Law Review, 193).This column was first published in NZ Lawyer magazine.

Topics: Privacy tort | Comments Off on Should we have a tort of intrusion?

Well, you would be, wouldn’t you?

February 20, 2012

Lovely NZ Herald headline:

Man critical after being set on fire

Topics: General | Comments Off on Well, you would be, wouldn’t you?

Offensive offence

February 16, 2012

A few years back, the censor banned this T-shirt (scroll down) depicting a masturbating woman and the words “Jesus is a cunt”. I questioned the ban.

Now the retailer who sold the T-shirts has been convicted for possessing them. I note that this offence also applies to everyone who owns such a T-shirt, whether they wear it or not. Are they to be prosecuted too?

Topics: Censorship, NZ Bill of Rights Act | Comments Off on Offensive offence

Lawyer’s name suppression bid fails

February 13, 2012

Criminal lawyer Barry Hart’s long attempt to have his name suppressed for his disciplinary tribunal charges has failed at the final hurdle, having also failed pretty much all the hurdles before that. The Supreme Court said:

The likely particular impact of publicity on [the person applying for suppression] will always be relevant, but it is untenable to suggest that professional people of high public profile, such as the applicant, have anything approaching a presumptive entitlement to suppression.

Topics: Name suppression | Comments Off on Lawyer’s name suppression bid fails

Online defamation: is it any different?

January 30, 2012

This is my column in NZ Lawyer magazine for 27 January 2012.

Are the laws of defamation different online?I’m picking this question is going to garner increasing debate in the next few years. The answer, of course, is straightforward. Ask any blogger (they are seldom shy of venturing legal opinions) and they’ll tell you that there are no laws of defamation online. It’s a wild west, a free-for-all. Cyberspace exists beyond the jurisdiction of the courts.

Alas, the courts seem to pay little respect to this line of jurisprudence. Early on, it was apparent that anyone who believed the online world somehow gazumps defamation laws was in for a nasty surprise. “I know no forum in which an individual has the freedom to say what he likes and in any manner he wishes about another individual citizen with immunity from suit for all consequences,” said Judge Ross in 2001. “Merely because the publication is being made to cyberspace does not alter this.” (O’Brien v Brown [2001] DCR 1065).

That’s your standard legal analysis. It’s still the best starting point. But a few recent cases suggest that things may be starting to shift a bit. Some judges seem receptive to an argument that readers of some online postings won’t take them seriously. This has been described as the “ALL-CAPS” defence to defamation.For example, Eady J commented that bulletin board postings were “often uninhibited, casual and ill-thought-out; those who participate know this and expect a certain amount of repartee or ‘give and take.’”  He said that some inflammatory comments might be taken as mere vulgar abuse and therefore not taken by reasonable readers as intended to be accurate (Smith v ADVFN Plc [2008] EWHC 1797 QB).

More recently, a superior court judge in Ontario issued a remarkable decision granting summary judgment against a plaintiff for an attack against him made on a website (Baglow v Smith 2011 ONSC 5131). He was a prominent political blogger called, for reasons best known to himself, “Dr Dawg”, though it was well known that his real name was John Baglow. Baglow argued that Omar Khadr, a 15-year-old Canadian national captured by US forces in Afghanistan and taken to Guantanamo Bay, should be repatriated. A right-wing blogger accused Baglow of being “one of the Taliban’s more vocal supporters”. In fact, Baglow had frequently criticised the Taliban as dangerous, theocratic and tyrannical.

The judge found these words were protected by the defence of fair comment (here, honest opinion). Maybe that’s so. But he also found that they weren’t defamatory in the first place. How did he figure that? His most convincing justification was that readers would think that “one of the Taliban’s more vocal supporters” was not literally true but merely shorthand for “he’s effectively helping the regime.” Still, that’s not enormously convincing. For one thing, it’s not clear why readers would reach that conclusion. For another, it still seems a bit defamatory. Most importantly, the judge’s job was to weed out meanings that the words were incapable of bearing. Can it really be suggested that those words weren’t capable of meaning…  just what they said? The judge seems to have usurped the jury’s function, which was to determine the actual meaning.

But the judge then lists other, even more interesting, reasons for his conclusion:

Internet blogging is a form of public conversation. By the back and forth character it provides an opportunity for each party to respond to disparaging comments before the same audience in an immediate or a relatively contemporaneous time frame. This distinguishes the context of blogging from other forms of publication of defamatory statements…

He said in many online environments, readers expect cut and thrust. They expect a defamatory statement to be parried. He said a “simple rejoinder” (he even went to the trouble of drafting one) could have “nipped in the bud” the risk to the plaintiff’s reputation.

In essence, I am suggesting that the Court, in construing alleged defamatory words in an ongoing debate, should determine whether the context of the comment from the perspective of the reasonable reader or listener is one that anticipates a rejoinder, which would eliminate the possible consequence of a statement lowering the reputation of the plaintiff in their eyes.

This seems to involve heroic assumptions. Why would readers necessarily discount an unrebutted statement? Why would a rebuttal necessarily undo all the harm? Still, putting aside its lack of coherence (it’s under appeal) the decision can still be seen as part of a trend: it treats online speech as distinctive; it suggests the best remedy for harmful speech is further debate; it incentivises rights of reply; it may reflect a sense that that the ICBM of defamation law is an inappropriate response to an online foodfight.

A US judge last year also refused to recognise online attacks as harmful. A bankruptcy specialist working at Obsidian Finance sued the author of “obsidianfinancesucks.com” (Obsidian Finance Group v Cox USDC, Oregon, 23 August 2011) for calling him a fraudster, thief, and liar who had engaged in corruption, pay-offs and cover-ups. The judge said that blogs “are a subspecies of online speech which inherently suggest that statements made there are not likely provable assertions of fact”.

Bear in mind that in the US, the First Amendment gives statements categorised as opinions a bulletproof jacket against defamation suits. And it’s certainly true that the blogger used lots of capitals, bold type and hyperbolic language, which many would have seen as clues to her credibility.

Still, the implicit assumption that inflammatory blogs are so overheated as to be self-evidently harmless seems questionable. I’m inclined to think a proportion of us (not me or you, of course) are credulous enough to lap this sort of attack up. Others may at least wonder whether there’s any fire under all that smoke. Are the victims of such attacks to be left without remedy?

Which takes us again back to the Law Commission’s search for the Holy Grail: a speedy, effective, and cheap means of determining online disputes like this. Should we set up a Communications Tribunal or Commissioner? The Commission is still taking submissions…

Topics: General | Comments Off on Online defamation: is it any different?

Silly old TVNZ

January 27, 2012

This is why I don’t like doing TV. I gave TVNZ news an interview on the teapot saga yesterday, explaining my views as below that the risk is low for anyone who publishes the contents of the tape.

Their broadcast asserts as a fact that “we can’t broadcast what was said for legal reasons”. Later the reporter says “legal experts” (who are the others, I wonder?) say police will struggle to charge the leakers, and then there’s me saying that it’s hard to see how the police could prove the publishers knew they were publishing an illegally obtained recording. Of course, that also applies to the media, not just the leakers.

So why is it that TVNZ can’t publish for legal reasons?

Topics: Internet issues, Journalism and criminal law, Media ethics | Comments Off on Silly old TVNZ

Teapot pours out

January 26, 2012

Someone’s put the teapot tape online. That’s the conversation between the PM and ACT candidate John Banks that cameraman Bradley Ambrose said he inadvertently recorded, during the most covered cuppa in NZ history.

The media, and even many bloggers, seem hesitant about linking to it. I’m not.

Here’s why. Put aside the question of whether it was in fact an offence for Ambrose to have recorded the investigation. The police are investigating that, and the High Court has refused to rule on it. The question is whether the media (and new media) can publish the contents. Now, it is an offence to intentionally disclose an illegally intercepted private communication – but only if you know that it has been illegally intercepted. If anyone wants to prosecute me, they’ll have to prove those two things beyond reasonable doubt.

And here’s the thing: I don’t know that it was an illegally intercepted private conversation.

What I know is that several experts (like Dean Knight and Andrew Geddis) have argued that it can’t possibly have been. The police would have to prove, beyond reasonable doubt, that Ambrose intentionally recorded the conversation. The police would also have to prove, beyond reasonable doubt, that the conversation was private – that is, that Banks and Key ought not to have reasonably expected it to be overheard.

It seems to me that there’s plenty of doubt about whether an offence has occurred. Ambrose says that he recorded it inadvertently. And there were 25 journalists around with powerful microphones very close by. I think that at best the case against Ambrose is arguable and on my best assessment of the law, I think it will fail.

I also think that a Bill of Rights-consistent reading of the law would allow publication by media in these circumstances, and the police’s prosecution guidelines would suggest that it’s futile to take action against anyone. I don’t think the legal risk is high for anyone in publishing or linking to the contents of the tape.

[I also note that if it’s an offence to publish or link to the contents now, it was also an offence for Winston Peters to disclose – and the media to report – the contents (and in fact, even the existence) of the recording last year. There’s been no suggestion that I’ve heard of any criminal investigation into that. What’s more, as far as the law’s concerned, there’s no difference between linking to the material and describing any of its contents. Some media seem to be pussy-footing around, telling us a bit about what the tapes say but declaring that it’s illegal to publish them directly. But they can’t have it both ways. Both are disclosing the contents – if one’s an offence, both are.]

Given that the tape is not particularly damning for the PM or Banks, and has now been widely listened to online, I wonder whether they shouldn’t just bite the bullet and consent now…

Topics: Journalism and criminal law, NZ Bill of Rights Act | Comments Off on Teapot pours out

Confessions of a tabloid journalist

January 17, 2012

For those who just caught be on Nine-to-Noon, those who’ve read Nick Davies’ excellent Flat Earth News, and those who are just interested in what goes on behind the scenes at UK tabs, here’s an insider’s expose, from former Daily Star journo Richard Peppiatt, who gave evidence to the Leveson inquiry.

Highlights: journalists never take a bit of notice of the Press Complaints Commission Code, they don’t give a stuff about the odd ruling against them, many stories are basically just made up or exaggerated beyond recognition, and stories are cut to fit the ideology of the paper. Oh, Peppiatt was once asked to track down Susan Boyle and propose to her. (She told him to piss off).

You might also be interested in his resignation letter.

Topics: Media ethics | Comments Off on Confessions of a tabloid journalist


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