The following is a paper, produced for a media law and ethics class on a chosen court case related to the class text. The paper and presentation represents 1/3 of the final grade for the class. This afternoon the presentation was presented, both it and the paper received glowing remarks from the professor.
Despite the grade for the paper not yet being received (should happen in a about a week), based on her remarks, we'll call this an "A" paper (anticipating at least a 95% based on the notes on the paper).
[*update 11/25: The paper received a 100%, the presentation 92%, for a weighted total grade of 97.36%]
Personally, the paper is pretty damn good and chock-full of goodness.... But you be the judge...
You can download it here if it makes it easier to read as a .pdf on a mobile device: https://drive.google.com/file/d/0B0L6-YMPxtu7bE1kRWM2VV9RQjg/view?usp=sharing
or read it here:
Kowalski v. Berkeley County School, Cyberbullying and Hate Speech Legislation
Due in part to the proliferation of digital
communication over the years, there has been growing concern over free speech
and free expression in relations to First Amendment rights and cyberbullying. “Cyberbullying”
can be defined as communication conduct employing technology devices used to
cause emotional stress and fear[1]
in a way that is “[meant] to intentionally harm [or embarrass] others”. Cyberbullying
is acted out using “hostile behavior such as sending [disparaging] text
messages and posting ugly comments on the internet.”[2]
Cyberbullying also includes a range of online conducts, including any
communication that is meant to instill hatred in the hearts and minds of others,
or humiliate or damage a victim’s reputation. Despite the damaging nature of
cyberbullying, it has yet to be labeled hate speech in the United States, which
in most cases is protected under the First Amendment[3].
However, in over a hundred and seventy five countries, many of them democratic,
hate speech is a crime and punishable by law.[4]
The First Amendment
states, “Congress shall make no law […] prohibiting the free exercise thereof;
or abridging the freedom of speech”. However, there are caveats to this, such as
incidents relating to clear and present danger, obscenity, incitement of
violence, libel/defamation, and fighting words[5].
Additionally, free speech is subject to restrictions dictated by time, place,
and manner. A new frontier of litigation based on inalienable rights has begun
to spawn thanks to the internet, where the protections of the First Amendment are
being applied to the World Wide Web.
In recent years, the instances of cases in the United
States involving internet harassment, cyberbullying and hate speech have
increased. Until recently,[6]
appeals have been unsuccessful in reaching the Supreme Court, most cases ending
at appeals in the lower courts of law.
One of the latest civil case that was unsuccessful in
gaining an appeal through the Supreme Court was Kowalski v. Berkeley County Schools 652 F.3d 565 (2012). Kowalski v. Berkeley made it to the United
States Court of Appeals of the Fourth Circuit in the North District of West
Virginia, but was not granted petition for writ of certiorari when she tried to
appeal her case to Supreme Court.
Kowalski took legal action against the school district
through the District Court, citing the First and Fourteenth Amendment, for disciplinary measures related to the creation of a 2007 group webpage created
on the online social networking site MySpace. The MySpace group page was generated
as a platform to encourage other students, along with Kowalski, to embarrass
and/or defame a fellow classmate. The short-lived online group was called
S.A.S.H. – an alleged acronym for “Students Against Shay's Herpes”. After
school authorities were alerted to the nature and scope of the webpage, the Musselman High
School senior was suspended from school for ten days and from all school
activities for ninety days, in which she was not a principle participant.
The Plaintiff, Kara Kowalski, filed suit under civil
rights law 42 U.S.C. § 1983 – a civil action for deprivation of [Constitutional]
rights. In her petition, Kowalski asserted “that the School District [Defendant]
was not justified in regulating her speech because it did not occur during a
‘school related activity,’ but rather was ‘private out-of-school speech’”[7].
Second to the infringement on free expression, Kowalski sought redress due to
infliction of “emotional distress” due to “social isolation”, which allegedly resulted
in depression and a subsequent need for medication. The Defendants responded by
filing for a dismissal and summary judgment. In turn, the court granted summary
judgment on the free speech matter.
During the proceedings, the District Court established
that Kowalski was fully aware of Berkeley County School’s statute related to
bullying, which was outlined in the School Code of Conduct, and therefore upheld
the disciplinary action by the school. The District Court contended that the
speech disrupted the environment of the school, negatively impacting the
learning environment. Finding no breech of First Amendment rights and no
grounds for “emotional distress”, the summary judgment by the District Court held
in favor of the Defendant.
Kowalski then moved to appeal the decision of the U.S. Fourth
Circuit Appellate Court. She
petitioned on the same grounds that the speech in question took place “out-of-school”,
and therefore the resulting discipline was unwarranted and caused undue
emotional harm.
The Fourth Circuit reviewed the case and upheld the summary
judgment of the district court under case law established by applying Tinker et al v. Des Moines Independent
Community School District et al 393 U.S. 503, 506 (1969). In the earlier
case it was established that free speech in school was only protected as far as
it was not disruptive, and that “school administrators have some latitude in
regulating student speech to further educational objectives”. Further, in the published verdict it was
established that “a court could determine that speech originating outside of
the schoolhouse gate, but directed at persons in school and received by and
acted on by them, was in fact in-school speech.”[8]
The Fourth Circuit also applied the Sixth District judgment from Lowery
v. Euverard, which established the duty of school administrations to foster
“safe school environment[s] conducive to learning”. [9]
Based on this, the School District was within its legal right
to discipline Kowalski for the aggressive online behavior. The Fourth Circuit
Court of Appeals agreed with the judgment of the District Court that Kowalski
had sufficiently disrupted the learning environment, which negated her First
Amendment rights. Therefore, the Fourth Circuit stood by all rulings made by
the lower court. Following the judgment by the Fourth Circuit, Kowalski
petitioned the Supreme Court for an appeal. However, the court denied her petition
for certiorari, therefore all judgments established by the District Court and
the Fourth Circuit Court stand.
Precedent for future lawsuits related to cyberbullying
will likely be established by the judgment made in Kowalski v. Berkeley County Schools. Most cases involving
adolescents and school discipline related to free speech issues have been known
to summon Tinker to determine the level
of First Amendment protection.[10]
In regards to free speech rights among adolescents, now both in and outside of
school, disruption or interference takes primacy over the protection granted to
what can be termed by some as “offensive speech”. This is largely in part due
to proliferation of social media and the broad community reach aided by the
internet. Other cases regarding free expression and students have also generally
applied standards set forth by cases such as Bethel Sch. Dist. No. 403 v. Fraser, 478 U.S. 675 (1986), in which
a student used “obscene” language and “graphic sexual metaphor” during a school
assembly[11].
There is a growing amount of litigation related to
electronic communication and cyberbullying in the United States. This can be
attributed to the prevalence of ownership of electronic devices such as
smartphones and tablets among adolescence[12].
Historically, there has been numerous court cases
related to the First Amendment, however, litigation due to cyberbullying is
relatively new compared to traditional bullying; until recently there have been
very few legal cases related to this problem. In most, if not all cases, First
Amendment rights were invoked as a defense by the perpetrator. The matter of
cyberbullying is not a behavior limited to the youth, but increasingly by adults.
The new era of technology takes workplace bullying and relationship issues, where
there is often threats and perceived intent to harm, into cyberspace. According
to the Workplace Bullying Institute, thirty-five percent of adults report being
bullied at work[13]. A
study by Pew Internet Research found that forty percent of adults have
experienced harassment online indicative of cyberbullying, varying from name
calling, to purposeful intention to embarrass, to physical threats, sexual
harassment and stalking[14].
While the cases of adult cyberbullying are more rare than those involving
adolescent, an upcoming Supreme Court Case Elonis
v. United States[15]
will consider the case in relation to the First Amendment. Using the judgment
of Virginia v. Black[16],
Elonis v. United States is set to establish increase legislative guidance
regarding adults and harassment or bullying online. Among other things, the Elonis case involves the legal precedent
of perceived online threats as protected free expression. According to Adam
Liptak of The New York Times, the ruling of the Supreme Court could have a
significant impact on future prosecutions related to electronic communication.[17]
Cyberbullying laws have been in existence for less than
ten years. The first state cyberbullying statute came out of Missouri in
response to the famous case of Megan Meier, a girl who committed suicide after
being bullied online by a classmate’s mother. The resulting lawsuit, United States v. Drew[18],
set an example for future state laws. As of September 2014, forty-nine
states* and the District of Columbia have bullying laws in place. Of those
states, forty-eight include “electronic harassment” and twenty of them include
“cyberbullying” with three additional states currently proposing laws. Several instances
of cyberbullying that resulted in the suicide of the victims also inspired
bills such as “The Megan Meier Cyberbullying Prevention Act” (Missouri); “Pheobe’s
Law” (Massachusetts); and “Act Toward Bullying Prevention” (Vermont)[19].
On the Federal level, there exists no exact bullying
laws; however, there has been a proposed Federal law regarding “cyberbullying”
since 2009. Additionally, “internet harassment” law, which includes sanctions
related to bullying under Section 875 of the U.S. Code, stipulates that threats
of harm communicated directly by any
means is a criminal act[20].
These laws illustrate a clear trend toward curtailing the scope of the First
Amendment, both online and off-line.
Cyberbullying is hateful by nature and is not just about
the insecurities of the bully, or any of the many reasons people are purported
to bully, nor is it purely about power and intimidation over peer-groups.
Sometimes bullying is often directed towards those perceived as “different”
from others, such as is related to race/ethnicity, gender, religious
affiliation, and sexual preference[21].
Cyberbullying and hate speech are synonymous topics in academic writing, and
are often combined under similar legislation in other countries. While hate
speech is harder to define than cyberbullying, it can be established through
definition alone that cyberbullying and hate speech are of similar ilk, and they
can be used interchangeably in reference to regulations and law in the United
States and around the world. Trends around the world have been towards
eradicating, or in the very least discouraging, all manner of hate speech and (cyber)bullying.
In the realm of jurisprudence, cyberbullying becomes a
matter of ethics[22]
versus law, as cyberbullying blurs the line between hate speech and free
expression, that of human rights versus civil rights. Regulating hate speech has
become commonplace among developed countries under human rights authority.[23]
As Webb states in Verbal Poison-Criminalizing
Hate Speech, Canada may have what appears the most balanced position
related to human rights and democratic rights of free speech. Canada’s criminal
code states that “identifiable groups [are] protected [including] those based
on race, national or ethnic origin, color, religion, age, sex, sexual
orientation, marital status, family status, disability, and conviction for
which a pardon has been granted”[24].
This criminal code also allows for providing provisions for things such as
truth, public benefit, or interest, and good faith based on religious grounds;
as with in the United States, Canada’s Supreme Court considers the cases. In
terms of cyberbullying, as with bullying, activities such as criminal
harassment, uttering threats, and intimidation are classified as Criminal Code
offenses[25]. Like
with state legislation, provincial statues are more prevalent in relation to their
federal/governmental law.
Germany’s hate law protects against libelous,
disparaging, and otherwise defamatory or damaging speech, including that related
to the deceased, with provisions against malicious speech inciting animosity
based of nationality, race, religion, or ethnicity.[26] Australia,
United Kingdom, South Africa, France and the Scandinavia countries have
anti-hate speech legislation, some as far back as the late 1800’s, like Singapore,
each with levels of regulation, but regulation nonetheless. According to
Felman, in Hate Speech and Democracy,
this makes the United States “an outlier among advanced democracies”, where “dignity
describes an individual's assurance that he or she fully belongs to the society
and will be treated respectfully, as a political and legal equal” – this brings
to mind tenants of Democracy. Other countries follow suit with similar statutes
as Canada loosely related to cyberbullying but “do not have stand-alone
offences”[27]
like many states in the United State - rather they have laws similar to Canada,
such as is the case with the United Kingdom, Australia, and New Zealand.
While there is less top-down regulation, the growing
number of school districts, cities, and states/provinces, indicates a bottom-up
attempt to address cyberbullying. Some schools have even created online
awareness campaigns and courses like “Understanding and Addressing Bullying”,
such is the case with one school in California[28].
Moreover, these actions illustrate a clear worldwide acknowledgment of the growing
issue of cyberbullying and hateful speech.
Among the concerns in public debate, outside of the First
Amendment implications on free expression, are the ethical, social and
emotional consequences[29]
related to cyberbullying and hate speech abound, due to the innate aggressive
nature of bullying. According to some studies, there is a clear distinction
between offline and online bullying, and therefore this warrants not only
further research but also special consideration in prevention of such behavior.[30]
With any perceived impediment on Constitutional rights,
there is a vast range of public and legal arguments. The primary argument of
the opponents of anti-bullying legislation is that anti-bullying or anti-cyberbullying
legislation fosters the “chill effect” created by the regulations[31].
They feel that this perceived chill effect prohibits students, and adults, from
feeling that they can freely express themselves and their ideas. Proponents of
these legislations may argue on what can be interpreted as ethical grounds. This
ethical standpoint is related to the encouragement of a healthy society in
which tolerance of hatred, harassment, and bullying is damaging and one where
it “manifesting bigoted views [impairing] progress towards being socially
well-ordered” which Simpson attests, vis-à-vis Waldren, “is something the law
can intervene in and counteract.”[32]
The main issue that evolves from the legal protection of
damaging behavior under the pretense of First Amendment rights is the idea that
all unpopular opinions have an
underlying value to them, and are therefore worth protection. In fact, those
that protect hatred of groups of people, or a single person, based on any
natural quality, is not valuable to a Democratic society, as earlier
illustrated by Felman, from ethical standpoints. Those who protect hate and
bullying under the guise of protecting “diverse opinions” would better be
suited acknowledging how it infringes of the victim’s right to dignity and “how
contributes to (identity-based) [damaging] social hierarchies”[33].
Reflecting on the work of Heyman, Simpson contends that hate speech and
cyberbullying are a violation, and such behavior diminishes social standing and
inflicts harm on the target. As Webb asserts, “hate speech regulation [and
thereby bullying regulation] is consistent with the democratic principles of maintaining
order, promoting equality, and protecting minority groups. Permitting hate speech
[…] actually works to counter these principles.”[34]
To further contextualize the point, the “right to freedom of speech [carries]
with it a responsibility not to jeopardise [sic] or undermine, in one’s speech,
the civic bonds that hold society together.”[35]
When applied to the cyberworld, what holds true in the
“real world” so shall it be online. The World Wide Web, long been touted as a
new frontier to Democracy, is not exempt from the tenants put in place by
regional, national and global laws, or agreed upon rules of ethics and morals. In
the real world, unethical behavior (generally) has consequences – both legal
and non-legal. First Amendment rights have never been absolute; such is the
case with caveats relating to ‘clear and present danger’, and ‘fighting words’.
Additionally, ‘libel’ is not a protected form of speech. Libel can be seem as
closely aligned with acts of bullying and hate speech, as libel is also damaging
and degrades the “widely-shared understanding and acceptance among the populace
of the status-respect that we all owe, and are owed, as fellow members of
society”.[36]
Alas, as Slagle[37]
contends, what is left is the question of who gets to decide. By ethical
standards, the principles of utilitarianism can be applied. What is a benefit
to the most people? Based on democratic principles, less bullying, less hatred,
less aggressive discourse is more beneficial to society as a whole than not, by
the sheer lack of value in cyberbullying. The answer then is in the ethics and
morals, as many other countries have contented by enacting laws to prevent
behavior that is damaging to their societies. As far as the future of
cyberbullying legislation in the United States, we have but to wait and see. What
will emerge will be up to the Court’s interpretation based on longstanding
First Amendment rhetoric and previous court judgments. It may not reflect the benefits of society and Democracy, but rather
the longstanding tradition of primacy towards “protected” rights of the individual.
Nor is it likely that the ethical implications of the matter will be in built
into the framework. What can be said
is that judgments on cases such as Kowalski
v. Berkeley County Schools will be key in raising the bar.
Footnotes:
[1] National White Collar
Crime Center. Cyber-Bullying The Legislative Response. National
White Collar Crime Center.
[2] "Cyber Bullying Law
& Legal Definition." Cyber Bullying Law & Legal Definition.
[3] Packard, Ashley. "Sex
and Violence." Digital Media Law. 2nd ed. N.p.:
Wiley-Blackwell, 2013. 330. Print.
Packard’s definition of hate speech is “communication
that disparages individuals or groups on the basis of characteristics such as
ethnicity, race, religion or sexual orientation”.
[4] See 3
[5] Chaplinsky v. New
Hampshire, 315 U.S. 568 (1942) “offensive, derisive or annoying word[s] to any
other person who is lawfull in any street or public place. . . with
intent to deride, offend or annoy him.” via Webb, Thomas J. "Verbal Poison
- Criminalizing Hate Speech: A Comparative Analysis and a Proposal for the
American System.
[6] Elonis v. U.S. is set to
go before the Supreme Court in 2015
[7] Kowalski v. Berkeley
County Schools, 652 F.3d 565 (4th Cir. 2011)
[8] Tinker v. des Moines
Indep. Community Sch. Dist. 393 US 503 (1969)
[9] Lowery v. Euverard 497 F.3d 584 (6th Cir. 2007)
[10] J.S. v. Blue Mountain School District (2011 & 2012), Doninger v. Niehoff (2011), People v Marquan M. (2014)
[11] "BETHEL SCHOOL
DISTRICT NO. 403 v. FRASER." Bethel School District No. 403 v.
Fraser. Chicago-Kent College of Law
[12] National White Collar
Crime Center. Cyber-Bullying The Legislative Response. National
White Collar Crime Center.
[13] Namie, Gary. "2010
& 2007 U.S. Workplace Bullying Surveys WBI-Zogby."Workplace
Bullying Institute (n.d.): n. pag. Workplace Bullying Institute.
[14] Duggan, Maeve. Pew
Research Centers Internet American Life Project.
[15] "Elonis v. United
States." SCOTUSblog. Supreme Court of the United States
[16] Virginia v. Black, 538 U.S. 343, 123 S. Ct. 1536, 155 L. Ed. 2d 535 (2003)
[17] Liptak, Adam.
"Supreme Court's Robust New Session Could Define Legacy of Chief
Justice." The New York Times.
[18] 259 F.R.D. 449 (C.D. Cal. 2009)
* Montana is
the exception
[19] See 12
[20] See 12
[21] "Why Do People
Bully?" Bullying Statistics. N.p., n.d. Web. 26 Oct. 2014.
[22] Slagle, Mark. "An
Ethical Exploration of Free Expression and the Problem of Hate Speech."
[23] Webb, Thomas J.
"Verbal Poison - Criminalizing Hate Speech: A Comparative Analysis and a
Proposal for the American System
[24] See 22/Canadian Criminal Code § 319
[25] Report to the
Federal/Provincial/Territorial Ministers Responsible for Justice and Public
Safety.
[26] See 12
[27] See 25
[28] Repa, Barbara Kate.
"E-Cruelty: Cyberbullying in California." California Lawyer (2013):
n. pag. E-Cruelty: Cyberbullying in California.
[29] Law, Danielle M.,
Jennifer D. Shapka, José F. Domene, and Monique H. Gagné. "Are Cyberbullies Really Bullies? An
Investigation of Reactive and Proactive Online Aggression."
[30] See 29
[31] Hayward, John O. "Anti-Cyber Bullying Statutes: Threat to
Student Free Speech."
[32] Simpson, Robert Mark.
"Dignity, Harm and Hate Speech." Law and Philosophy
[33] See 32
[34] See 25
[35] See 32
[36] See 32
[37] See 23
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and Philosophy 32.6 (2013):
701-28. Springer Link. Springer, 27 Nov.
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Proposal for the
American System."Washburn Law Journal 50.2 (2011):
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