FC: Mailing list operators not liable for libel, Public Citizen argues

From: Declan McCullagh (declanat_private)
Date: Thu May 16 2002 - 20:05:43 PDT

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    Date: Thu, 16 May 2002 12:57:55 -0400
    From: "Paul Levy" <PLEVYat_private>
    To: <declanat_private>
    Subject: Libel claims against listserv operators
    
    I want to call your attention to a brief as amicus curiae that we recently 
    filed in partial support of the appeal of Ton Cremers, the operator of 
    Museum Security News, from the refusal of a trial judge in California to 
    dismiss a libel action filed against him based on the contents of an email 
    message that he included in his MSN Newsletter and web site.  The message 
    accused a woman of bragging that she was descended from a Nazi bigwig and 
    of having hundreds of paintings which, the message claimed, had been stolen 
    from the Jews during World War II.  Thus, the message itself was plainly 
    defamatory, and the plaintiff was and is surely entitled to complain about 
    having her name blackened by the author of the message.  But Cremers argued 
    that, as a listserv operator, he was immune from liability under the 
    Communications Decency Act and, hence, the suit against him should be 
    dismissed under the California SLAPP law.  The judge refused to dismiss the 
    claim on the ground that only ISP's that afford access to the Internet, 
    such as AOL, can be immune under the CDA.
    
    Our brief argues that, like the operators of web site message boards, the 
    operators of genuinely interactive listserv's should enjoy immunity under 
    the CDA.  The proposition that only ISP's like AOL are immune under the CDA 
    is plainly wrong.  We also support Cremers argument that, even though 
    appeals may normally be taken only from a final order that ends the case, 
    and not from denial of a motion to dismiss, he is entitled to appeal 
    immediately, without waiting for the case to go to trial, because the whole 
    purpose of both CDA immunity and the SLAPP law is to protect persons who 
    exercise their right of free speech against having to undergo the burdens 
    of litigation in cases that lack legal or factual merit.  (The plaintiff 
    had previously move to dismiss the appeal for lack of appellate 
    jurisdiction; we participated in the argument on that motion as amicus 
    curiae and the motion was denied with leave to raise it again in the briefs 
    on the appeal itself).
    
    On the other hand, we express concern that the record on appeal is too 
    skimpy to permit the Court of Appeals to satisfy itself that Cremers' 
    newsletter is, in fact, an interactive listserv, and so we urge the Court 
    to remand to allow the district judge to develop a more complete factual 
    record on the issue of interactivity.
    
    Our brief is available on the Internet Free Speech portion of our web site 
    at http://www.citizen.org/documents/CremersAmicusBrief1.pdf.  A press 
    release about the brief can be viewed at 
    http://www.citizen.org/pressroom/release.cfm?ID=1114.
    
    
    Paul Alan Levy
    Public Citizen Litigation Group
    1600 - 20th Street, N.W.
    Washington, D.C. 20009
    (202) 588-1000
    http://www.citizen.org/litigation/litigation.html
    
    
    
    
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