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Howard Schweber

Howard Schweber

Posted: July 5, 2009 03:59 PM

Sarah Palin, the First Amendment, and Santa Claus


Dear Santa,

Sarah Palin, through her attorney, is threatening to sue Shannyn Moore for reporting the existence of rumors about a pending investigation of Palin's dealings with a firm called Spenard Building Supply and various contractors, in connection with the construction of the Wasilla Sports Complex and the Palin residence. The implication is that investigators suspect corruption. Palin categorically denies the implication and is threatening to sue for libel.

oh please, oh please, oh please

The basis for such a suit is clear. For too long we have witnessed the politics of personal destruction, the bloodsport of smearing a persons' reputation. The courts are the last resort, the place where the innocent can avenger her honor, save her reputation, and take some measure of revenge on her tormentors.

oh double please, oh double please, I'll be good for a whole year, I promise

Remember the lengthy list of hit jobs on Hillary? The accusations that Bill hired killers to murder his opponents and ran planes full of cocaine up from Latin America? Remember black helicopters? And how about the current incumbent, have you heard any false accusations about him? Well, Sarah Palin stands ready to ride tall into the sagebrush of the mountaintop ... wait a minute, I lost my metaphor....

remember that time I was ten and I really wanted a pony? I want this more. Much, much more.

Okay, I suppose I ought to make some pretense of a serious point. Here goes. The standards for a public figure suing someone for libel are set by New York Times v Sullivan (1964), as modified by Gertz v Welch (1974). The original Sullivan rule applied to political figures; the Gertz gloss extended it to "public figures" generally. The standard is that for a public figure to prevail in a libel suit, they have to prove that the statement in question was made with "malice," or at a minimum with "reckless disregard for the truth." In practice, that "reckless disregard" standard has been pretty well abandoned; the only way for a public figure to win a libel suit is to show that the party making the statement knew it was false.

The context of Sullivan is interesting. In 1960 a group of four African-American Alabama clergymen took out a full-page ad in the New York Times describing the brutal suppression of civil rights protests in Montgomery, Alabama. The ad specifically stated that police had "ringed" the capitol building and had used shotguns and teargas to dispel student protestors, that the entire student body had protested in response, and described the protesting students singing "My Country 'Tis of Thee" on the Capitol steps just before the police charged them. Commissioner of Police Sullivan objected. Cops had not actually "ringed" the Capitol; only most, not all, of the student body had protested. And! The students protesting on the Capitol steps did not, as the ad said, sing "My Country 'Tis of Thee"; they sang the national anthem.

That was the background. The Supreme Court did not want to see libel suits used by powerful politicians to intimidate and silence protesters. But then Gertz went further. Gertz involved a Chicago lawyer who represented the family of a young man killed by the police in their suit against the policeman involved. The John Birch Society disapproved; in their magazine, they charged that Gertz was a communist and that the lawsuit was part of a national conspiracy against law enforcement. In that case the Court applied the same Sullivan standard on the grounds that Gertz's activities made him a public figure. The Supreme Court's explanation was that a public figure has access to the media, and is therefore able to respond effectively to any accusations of wrongdoing or assertions impugning their character.

This is a singularly unsatisfactory explanation, particularly in the case of an involuntary public figure. Think Richard Jewell ... or Governor Palin's children. Do we really think that Bristol Palin or Chelsea Clinton are "public figures" in the sense that their parents are? Why should the fact that someone's activities bring them into the public eye mean that they are subject to the same level of rough criticism that we expect our elected officials to endure? No other country has embraced the Sullivan/Gertz standard; courts in Australia and New Zealand, for example, have explicitly singled out the American rule as one they did not want to see at work in their jurisdictions.

That American protection for free speech goes farther than that in other countries is a cause for celebration on this July 4th weekend. Nonetheless there are serious questions when involuntary public figures, or non-political public figures, or especially the family members of public figures are swept within the ambit of the Gertz rule.

But! Governor Palin isn't threatening to sue people who say bad things about her children, or even her husband. She is threatening to sue a blogger who accurately reported the existence of rumors of an investigation of wrongdoing by her in her at a time when she was already a government official.

Please-please-please. I'll never ask for another thing, I promise.

Now, I haven't practiced law in a while, and I do not have a current Bar membership. But I will go get one if Shannyn Moore will let me represent her. The thought of the deposition of Governor Palin alone is enough to make it worth the money, but that's only the tip of the iceberg; a motion for sanctions followed by a counter-suit for vexatious litigation is just begging to be heard.

Oh please, oh please, oh please. I'll do the dishes and put the cap on the toothpaste and everything.

Never mind Santa. Shannyn? Fellow Huffpo blogger? Are you listening? Pleeeeease?

Dear Santa, Sarah Palin, through her attorney, is threatening to sue Shannyn Moore for reporting the existence of rumors about a pending investigation of Palin's dealings with a firm called Spenard B...
Dear Santa, Sarah Palin, through her attorney, is threatening to sue Shannyn Moore for reporting the existence of rumors about a pending investigation of Palin's dealings with a firm called Spenard B...
 
 
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02:31 PM on 07/06/2009
As a law professor, you'd better re-read Gertz. The Supreme Court said he was not a public figure. No question Palin is, though.
02:40 PM on 07/06/2009
How embarrassing! Particularly since I not only sometimes teach First Amendment law, but I also wrote a book on the subject ("Speech, Conduct, and the First Amendment.") The dangers of thinking you know a case so well there is no need to review it before citing. Mea culpa.
01:46 PM on 07/06/2009
Could Bill Ayers sue sarah for defaming him? After all, he was not a public figure and has never been convicted of anything yet he was labeled a "terrorist" by palin.
02:24 PM on 07/06/2009
he is
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seanparnell
10:15 AM on 07/07/2009
No, he couldn't. Start with the inconvenient fact that Ayers was, by a reasonable definition, a "terrorist." That in and of itself would pretty much stop any libel/defamation suit by him.

But even if you can get past that, he was a public figure - quoted and covered in the media, a prominent academic whom I believe had written a book, etc. "Public figure" is not confined to those in public office - pretty much anybody who comes to the public's attention for any reason is in some way a "public figure."

Oh, and the "never convicted" thing doesn't matter - otherwise everybody who called Bernie Madoff a "crook" (or worse) before he was convicted would be in trouble. Or who called OJ a "murderer" - he was acquitted, you know.

Sean Parnell
President
Center for Competitive Politics
http://www.campaignfreedom.org
outnow
Ban the bomb
01:28 PM on 07/06/2009
Some of the best JFK testimony was preserved in Mark Lane's defense of a defamation case against a member of the press. Truth is a total defense. Recklessness and/or malice must be shown. I can show you malice on Palin's part in her every word. Every second year law student must know New York Times v. Sullivan standard. I cannot imagine passing the bar examination without being familiar with this concept. Too bad you can hold political office in America and not know what we expect high school students to know in Civics class but require all lawyers to know.

If you are too stupid to learn of this vital standard protecting the free press in high school, you just might learn of it in law school. Some slow learners must sue, and thereby "republish the defamation," repeatedly. A loss in court would only emphasize the truth of the matter asserted in the allegedly defamatory remarks.

Palin should go for it. Maybe she will learn a lesson that she should already know. What kind of role model are stupid politicians? It's not her fault that she is stupid but ignorance is unforgivable.
11:40 AM on 07/06/2009
I *do* have a current bar membership (in Illinois). This is a case I'd *love* to handle, if it were in Illinois, as it'd be a slam dunk.
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Jaxy
Bah! My micro-bio didn't meet your guidelines
10:04 AM on 07/06/2009
Like Prof. Schweber, I do not have expertise in First Amendment Law.

However, the thought of shaking it up with 'Precious Princess Palin' on this issue makes the motivation to go get that knowledge almost irresistible!
09:18 AM on 07/06/2009
I still liked the ducks on the lake behind her. It was just - lame.
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LeftRight
TANSTAAFL
07:08 PM on 07/06/2009
I heard those on the tape.... I kept expecting her to ask whose ringtone that was....
justobserve
Not left nor right or center. Just a free thinker!
09:12 AM on 07/06/2009
" The thought of the deposition of Governor Palin alone is enough to make it worth the money": Too true even if Palin would be an EX-Governor! Palin has had a record of quitting: from 5 years in different colleges for one degree forward to the present.
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10:42 AM on 07/06/2009
And...when she was appointed to the 'Oil and Gas Commission' as an 'ethics advisor', but she quit after only a year into her four year appointment. Because, she claimed, the Commission had no 'ethics'.
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BlackJAC
It's better to be a black king than a white knight
08:58 AM on 07/06/2009
I tend to go by the same standards THE SOUP uses when mocking someone: you don't get targeted unless you do something to warrant being targeted. Chelsea kept her head down the whole time and therefore was left alone. Conversely, Bristol was turned out as a prop for her mother's political ambitions despite being a damning example of the failure of the ideology-based sex education policies her mother espoused, and therefore got mocked.
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JustMyWords
05:40 PM on 07/06/2009
Actually, despite her parents' best efforts to keep Chelsea's head down, she was NOT left alone. Have you forgotten Rush Limbaugh referring to her as the "white house dog?" Or McCain's comment about her looks, and Janet Reno being her father?
08:55 AM on 07/06/2009
Calm down everybody. Sarah isnt going to win until 2012. So you can watch Obama spend all our money and give speeches everyday for the next three years.
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tc2598
10:33 AM on 07/06/2009
seven years, no question. Get comfy.
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skantea
A Resource Based Economy
06:16 PM on 07/06/2009
How much is that illegal War costing us again?
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LeftRight
TANSTAAFL
10:39 AM on 07/06/2009
Yeah, uh huh..... You go ahead and believe your delusions, and the rest of us will get on with saving America!
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mitsie
08:52 AM on 07/06/2009
Now I would love to see the discovery regarding that 1/2 million dollar home, where the building materials came from, who worked on the house, etc. Now I wonder if that alone is a deterent from suing?
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VOTER
Freedom from fear - the philosophy of human rights
08:44 AM on 07/06/2009
GREAT ARTICLE!

I'm going to write to Santa too.
: )
08:36 AM on 07/06/2009
I wonder which one of the Internets she'll try to sue first?
IWantTofu
Evolution. Now a political position.
08:36 AM on 07/06/2009
If the lawsuit goes to court, can the defendent then proceed with discovery forcing Sarah Palin to answer questions that she has been dodging in a potential corruption investigation? It would seem to me that a Palin initiated lawsuit woud automatically waive any fifth amendment claim regarding the potential crimes that Palin is involved with because the lawsuit asserts that she commited no crime. This may be the best thing to go ahead with the lawsuit. There is no way (I think anyway) that Palin can win, and it may force her to answer questions that she doesn't want to answer.
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JustMyWords
05:46 PM on 07/06/2009
There's a bit of merit to what you say.

There is no 5th amendment right that can be invoked in a civil suit. She COULD invoke the 5th, saying that her statements could incriminate her in any future criminal suit, but that's not exactly an option that would make her life easier. Or, more likely, she could just lie through her teeth and hope never to get caught - although lies made under oath in a civil case COULD be used in a criminal case.

The funniest thing, though, would be watching her try to find a lawyer that would take her defamation suit in the first place.
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Ann-Pittsburgh
Trying to be the person my dog thinks I am.
06:19 AM on 07/06/2009
I laughed till I cried, but I think these may be tears of relief: This poor soul is not a heartbeat from the Presidency.
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BigSlick674
Mitochondr­ial DNA has no expiration date
05:45 AM on 07/06/2009
Do you think Sarah resigned just so she could sue bloggers?

That would be more logical than the word salad Palin dumped in her back yard last Friday......