Not surprisingly, Court dismisses Patrick Reed's defamation suit - UPDATE: Court of Appeals also dismisses appeal

October 5, 2023

Back in August of last year I reported that professional golfer Patrick Reed filed a defamation claim against a number of defendants including commentators for the Golf Channel, and I explained how the complaint was a good model to teach how NOT to  draft a complaint.  See here.

The complaint was based on obviously wrong arguments and I predicted it would be dismissed.  My prediction was correct and the case was dismissed in November.  But the dismissal was without prejudice and, thus, Reed and his lawyers were given a chance to amend the complaint and try again.

They shouldn't have because, as I argued back then, the claim was flawed from the start; but they did.  

And, predictably, they lost again.  As expected, the court found that the alleged defamatory statements were either not defamatory, rhetorical hyperbole, true or substantially true, or statements of opinion.

You can read the opinion, which is pretty detailed and long, here.

UPDATE:  July 11, 2025 

Courthouse News Service is reporting today that the Court of Appeals for the 11th Circuit has (again, predictably) dismissed the appeal.  Go here for more on the story and a link to the one page order. 

Alex Jones must pay families of Sandy Hook shooting victims despite bankruptcy -- UPDATED

October 21, 2023

If you have been following the news about the lawsuit filed by the surviving families of the Sandy Hook school shooting against millionaire conspiracy theorist Alex Jones, you know that a Connecticut jury ordered Jones to pay $965 million in damages to 15 relatives of the victims.  Soon, Jones tried to weasel his way out of having to pay for the damages he caused by filing for bankruptcy.  

But I just learned that another judge has ruled that Jones can’t use bankruptcy protections to avoid paying money to the families of the victims. The Hill has more on the story here.

Unfortunately, it may be a while before the families see any of the money, but I hope they do sooner rather than later.  

UPDATE 10/27/23: Above the Law has an update and commentary here.

Rudy, that's not how anything works, Part III: Giuliani found liable for defamation by default

A few days ago, I posted a story questioning why Rudy Giuliani would concede the main elements of a cause of action for defamation he had been fighting (based on his comments about two election workers).  Giuliani -- or perhaps, more accurately, the lawyer representing him -- apparently thought that it was a good tactic in order to avoid complying with a discovery request, but that made no sense.  My original comment explaining why the tactic was likely to fail is here.  

As I predicted, the tactic not only failed, it backfired spectacularly.  See here.  First it resulted in an order to explain his argument and eventually in a finding of liability by default.

Maybe Giuliani and his lawyer did not realize that what they did amounted to conceding the main elements of the cause of action and for that reason, and because of the fact that they did not comply with discovery, the court has found Giuliani liable by default.   

Now that default judgment has been imposed, the case will move to trial on the question of the value of the injury, ie, on the damages issue alone.  And if you have been paying attention to the story in the news and have watched some of the testimony by the plaintiffs, you know it is fair to say that the value will likely be high.  Plus, Giuliani will have to pay attorneys' fees to the plaintiff's lawyers and more in sanctions.

Giuliani is in real trouble.  He is reportedly in dire financial trouble and a huge verdict against him in this case will cause him a lot of distress.  He has been trying to find funding for his legal bills, which include pending disbarment proceedings in New York and Washington DC, the indictment in Georgia, and at least one other defamation case.  Reportedly, Trump is not contributing to his defense fund and Giuliani has put up his NY condo up for sale and is hosting events in attempts to raise funds.  (Trump apparently agreed to appear in one of them, although I won't be surprised if he makes the appearance all about himself and ends up trying to get contributions for his legal defense fund rather than for Giuliani, but that's another story for another day.)

You can read the court's opinion here.  You can find reports and commentary on the default judgment against Giuliani in the following:

Courthouse News Service

The Legal Profession Blog

NPR

The Guardian

Above the Law

NPR audio

Jurist

MSNBC

Rudy, I told you that's not how things work!

 Last Friday I posted a story about how Rudy Giuliani attempted to prevent having to comply discovery in a defamation case by conceding all the elements of the cause of action against him and, at the same time, trying to raise defenses in the case.  And, after explaining the situation I concluded "Unfortunately for Giuliani, that’s not how anything works."  My original story is here.

I fully expected Giuliani's tactic to be rejected and that is just what happened.  Reportedly, the judge overseeing the case has given Giuliani the following options.  He can:

1.  submit a new stipulation conceding liability to the claims “all factual allegations ... as to his liability for plaintiffs’ defamation, intentional infliction of emotional distress, and civil conspiracy claims, and his liability as to plaintiffs’ claim for punitive damages” and that a default judgment as to his liability is appropriate, or

2.  explain why he is declining to submit such a stipulation by clarifying “what precisely his original stipulation conceded regarding the plaintiffs’ factual allegations and legal claims.”

Should Giuliani fail to choose one or two, the judge will convene a hearing (on August 15) to determine how, if at all, he has complied with her prior order to search and produce all materials responsive to the plaintiffs' discovery requests. 

Stay tuned!

MSNBC has coverage here.  TechDirt has a comment here.

Why would Rudy Giuliani concede the elements of a defamation claim against him?

Last Tuesday Rudy Giuliani filed a two-page stipulation in a long-running defamation lawsuit by two Georgia election workers stating that he “does not contest” that his statements about the plaintiffs were “false” and “carry meaning that is defamatory.”  According to the reporting, Giuliani’s attorney added that Giuliani was not in fact “admitting” to the plaintiffs’ allegations against him but making a decision to stop contesting them, which he says should end the plaintiffs’ effort to seek further factual evidence – emails, text messages and other communications – from Giuliani.

Unfortunately, for Giuliani, that’s not how anything works.

First of all, trying to make a distinction between conceding the allegations and not contesting them is nonsense.  You can’t have it both ways.  In the document, Giuliani conceded that he made the statements alleged in the complaint, that the statements were false and that they were defamatory per se.  That means he conceded all the elements of the cause of action. Period, end of story.  All Giuliani has left after that is arguing affirmative defenses.  And which ones are there?  I don’t see any.  

He apparently claims that either the statements were statements of opinion or that they were constitutionally protected.  Both arguments are wrong.  

Once he admits that the statements he made were “false” he has admitted they were not opinions.  By definition opinions can’t be true or false – that’s what distinguishes them from statements of fact.  But Giuliani has conceded they were statements of fact.  So that argument is out - he defeated it himself!  

The other possible argument – that the statements were constitutionally protected, is also flawed.  First, the notion of defamation is based on the doctrine that not all speech is protected and that if it is not protected, it can result in possible liability.  That’s what defamation law is all about.  So the question becomes whether the plaintiff can meet the standard needed to show that the speech is not protected and, therefore, should subject the defendant to liability.

On that, the doctrine has created different standards for different categories of plaintiffs.  If the plaintiff is a public official or a public figure, the plaintiff has to meet a higher standard because speech about them is more protected.  But the plaintiffs in this case were neither.  They were private persons performing a volunteer job as election officials.  I could be wrong about this, but I don’t think they were elected officials for that job, and they were not known celebrities before the elections and before Giuliani and others started accusing them of misconduct.  If I am correct in those assumptions, the plaintiffs in this case do not have to show actual malice on the part of the defendant and will have an easier time defeating the argument that the statements were constitutionally protected.   

Second, Giuliani can’t just say that he wants to end discovery because he does not want to disclose more information.  Discovery exists to allow the parties access to information and, as everyone knows, discovery is not limited to evidence that can be used at trial.  You can use discovery to get access to evidence that will likely lead to evidence that can be used at trial.  

The fact Giuliani says he is conceding the element of the claim to end the plaintiffs’ effort to seek further factual evidence just makes me wonder what he has that wants to hide so badly. 

And, further, defamation was not the only claim in this case.  The plaintiffs’ also sued for emotional distress which is a separate cause of action and they should have the right to continue discovery in order to get evidence related to that claim, which should include the evidence that Giuliani apparently does not want them to get access to.

For these reasons, it seems to me the decision to concede the elements of the cause of action was not a very smart one.  It defeats one of his defenses, makes it easier for the plaintiffs to support their claim and should not stop discovery.

Finally, as an aside, I also can't imagine that publicly admitting that he lied in a way that caused so much injury to private individuals is going to help Giuliani's chances to avoid discipline in the various disciplinary proceedings he is facing.

For coverage of Giuliani's confession see Politico, NPR, MSNBC, The Guardian, The Hill, The Conversation and Above the Law.

UPDATE: 8/9/23:  As expected, the judge did not buy it.  See here.

UPDATE: 9/3/23:   The story continues here.

OpenAI Sued For Defamation Over Statements Created by ChatGPT

It has finally happened: someone has sued ChatGPT maker OpenAI over an AI “hallucination” (i.e., confidently spewing out something that is blatantly wrong). The complaint, filed by Mark Walters, in state court in Georgia, argues that OpenAI made up false and defamatory claims about himself.   TechDirt has the full story here.

Golf and how not to plead a defamation claim -- UPDATED

August 26, 2022

Long time readers of this blog know that over the years I have posted many stories about golf related torts.  Go here and scroll down to see them.  Most of them relate to cases in which a golfer's negligence results in damages to another golfer or to a nearby property owner.  So today I bring you a golf story of a different sort.

If you know anything about professional golf, you know that there is a huge to do about the fact that a new professional tour (funded by Saudi Arabia) has been created to compete directly against the American PGA tour.  When a good number of top, established, PGA pro players signed to play with the LIV tour, the PGA banned them from playing in PGA events and the debate about the new tour started to get heated.

The availability of the LIV tour now threatens the PGA's control of the pro tour and its players, and the reaction to the competition has been very fierce on both sides.  PGA faithful players and commentators have spoken publicly against the players who defected to the LIV tour.  Players who defected have accused the PGA of many things...  etc.... ...  Insults and accusations are being thrown in all directions. ... You get the idea.

Enter Patrick Reed, a pro golfer who recently decided to leave the PGA and join the LIV tour.  For this, one of the commentators of the Golf Channel criticized him (and others) strongly over a series of broadcasts and Reed has now filed a claim for defamation.

That was a long intro for me to get to my point today.  If you want to learn how NOT to draft (or argue) a defamation claim, read the complaint now.

Here are some of the problems I see with the complaint. First, because of his celebrity golfer status the plaintiff will likely be considered a public figure so he has to meet a higher burden of proof against the defendants, who are members of the press.  Second, the complaint is full of conclusory statements characterizing the statements upon which it is based as "defamatory" with weak explanations as to how that conclusion is supported.  This is a problem because as alleged it is easy to point out that the vast majority, if not all, of the statements in question are not actionable because they are either statements of opinion (as opposed to statements of fact), insults or permissible hyperbole.  

And then there is the chance that maybe the judge could be convinced that the plaintiff is actually "libel proof" since his reputation is, well, not the best among many.  You can read more about the case and about Reed and his reputation here.  (As the author of that article says "It was a chain of suspicious incidents involving Reed and his golf ball, however, that smudged his image with a mark no eraser can fully eradicate.")

The complaint does have some statements that could be considered statements of fact (I think the point is debatable but I can see a judge not dismissing them for now) all of which relate to incidents in 2019 and 2021... and about those I wonder if they are affected by a statute of limitations.  

I am very interested in this case and I would like to see if the defendants file a motion to dismiss.  I would, and I think most if not all of the claims should be dismissed.  

---------------------------------

UPDATE (11-27-22):  In my original post I commented on how poorly the complaint in this case was drafted.  Not surprisingly, the court agreed and dismissed it.  The dismissal is without prejudice, so it is possible the plaintiff's lawyer may be able to fix it, but we will have to wait and see.  Here is the dismissal order.

I found out about the dismissal in the Golf Dispute Resolution blog, which includes a short comment that starts as follows: 

I typically question the wisdom of a public person with a questionable past filing a suit for defamation. The essence of defamation is damage to reputation. Thus, by commencing such a claim, plaintiffs invite inquiry into all aspects of their past. The damage calculation in many respects is a gap analysis: what is the difference between the reputation with and without the allegedly defamatory statements. A defamation claim can be the legal system’s warning that those living in glass houses shouldn’t throw stones.

Thus, like many, I was puzzled with Patrick Reed elected to take on Golf Channel and its media talent, Brandel Chamblee and Damon Hack, with claims that they had defamed him. Certainly, Reed’s history–including longstanding stories about alienation from his parents, issues with teammates during his college career, more recent suggestions that his on course professional play has included incidents of cheating–paint a large target on his back for defense lawyers eager to challenge claims that the broadcasters have damaged Reed’s reputation.

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UPDATE #2:  October, 2023

After the original complaint was dismissed without prejudice, the plaintiff filed a new complaint to try again.  They should not have since the basis of the claim was flawed, but they did.  And predictably, the case was dismissed again.  Go here for the story.

Good article on the defamation claims against Sydney Powell

 Over at Verdict, Michael Dorf (Cornell Law) has published a good comment on the defamation case against Sidney Powell.

In case you don't remember, Sidney Powell is the former lawyer for the Trump campaign who at one time promised to "release the Kraken," argued that the Dominion vote counting machines had somehow been rigged by Venezuela and that Dominion had bribed public officials in Georgia, among many other things. 

Some time later, Dominion sued her for defamation and recently Powell, through her attorneys, argued that her statements could not constitute defamation because they were so crazy that noone would believe them to be true.  

This defense is somewhat logical given defamation law, but also problematic because if the statements were so unbelievable, then she herself must have known they were not true when she affirmed them.  And, since she affirmed them is support of litigation, by making the defense in the defamation case she is admitting to either being incompetent or to having instituted litigation improperly, both of which can subject her to professional discipline (which I believe she is facing in at least one state).

But the article linked above is about the defamation claim and on the validity of the defense.  Go take a look at it.

Short article on the state of defamation law

Last month, the Texas Supreme Court rejected Alex Jones’ petition to review a lower court's decision to allow a defamation lawsuit to proceed against him.  The plaintiffs in the lawsuit are some of the parents of children who died in the Sandy Hook school shooting.  

In a short interview published in Above the Law, law professor Derek Bambauer, who coauthored an amicus brief to the Texas Supreme Court arguing that the defamation claim against Jones should proceed, talks about the case and the current state of defamation law in general.  You can read the interview here.

Trump campaign sues CNN

A few days ago, I reported that the Trump campaign had filed lawsuits against the NY Times and the Washington Post (here and here).  Today, the news is that they have followed up with a case against CNN.  TechDirt, which has referred to the claims as "laughable SLAPP suits" has the story here.

Trump campaign sues Washington Post

Last week I commented on the fact that the Trump campaign had filed a claim against the New York Times for defamation based on an Op-Ed piece.  See here.

Today I am here to tell you that they are at it again, having filed another (essentially the same) lawsuit this time against the Washington Post.

Marking what he calls a "less than noble moment," one commentator concludes that "the lawsuit is weak and unlikely to succeed."  See here.

Courthouse News Service, Jurist and Reuters have more on the story.

Trump campaign sues New York Times for defamation

Donald J Trump for President, Inc. (the official name of Trump's reelection campaign) filed suit against the New York Times for libel last Wednesday claiming defamation by the author of an Op-ed piece.  According to the complaint, the plaintiff's reputation was damaged by statements in the opinion article that there was an “overreaching deal between the Putin Oligarchy and the Trump campaign to help the campaign against Hilary Clinton.”

The reaction I have seen to the complaint has been consistent in that it is almost certainly guaranteed to fail, for the most part, because the article represents an opinion rather than an assertion of fact.  It has also been criticized as mere political hyperbole, not a complaint based on actual facts.

I agree that the case is likely to fail, although I think it can be argued that some of the statements in the piece can be read to assert facts rather than opinion.

What is more interesting to me is something else.  I wonder if the plaintiff's lawyers realize that if the case is not dismissed on a motion to dismiss and proceeds to discovery, the newspaper could serve Trump with a subpoena to appear in a deposition as part of discovery.  That would be fun to watch.

For comments on the complaint, check out the following:

Jonathan Turley ("The selection of an opinion piece makes this case especially difficult. . . .  In my view, the column is protected speech under the First Amendment.")

New York Personal Injury Law Blog ("First off, the complaint doesn’t start well as it’s supposed to be written with actual facts. This one is chock full of political hyperbole. . . . And most folks with functioning neurons — and I think most of our judges have them — know that when that kind of nonsense appears in a complaint it’s to mask the emptiness of the complaint.")

Courthouse News Service

Politico 

The Daily Beast

Podcast on internet defamation

The most recent edition of the podcast "Digital Detectives" is devoted to a discussion of what lawyers need to look out for when handling a defamation case that originates in comments made on the internet.  You can listen to the program by going here.

Devin Nunes files lawsuit for $250 million against Twitter; does it violate the rules against frivolous suits?

By now, I am sure you have heard all the jokes about the lawsuit filed by Rep. Devin Nunes.  If not, here is the bottom line: Rep. Devin Nunes has sued Twitter, some satire Twitter accounts, and a real political commentator for a variety of "offenses" including defamation based on allegations that anyone with a basic understanding of the law should know would not support a claim for defamation.  He is asking for $250 million in compensation.  The defamation claim is frivolous.

Of course, frivolous lawsuits are not new, but this is the same Devin Nunes who co-sponsored the Discouraging Frivolous Lawsuits Act and who once voted for a House Amendment "to express a sense of Congress that free speech should be protected."

For a detailed analysis of the complaint, go to TechDirt.

You can read more comments in ABA Journal, and The Daily Beast.

For the jokes I mentioned above, you can go here, and here for some examples.

Judge dismisses defamation suit against Trump

By now you have probably heard that a U.S. District Judge has dismissed a defamation lawsuit filed by Stormy Daniels against Donald Trump based on a “tweet” in which Trump suggested Daniels lied. 

The judge concluded that the tweet "constitutes 'rhetorical hyperbole', and that because the tweet displays “an incredulous tone,” it was not meant to be understood as a “literal statement about the plaintiff."

You be the judge.  The statement in question is this:  "A sketch years later about a nonexistent man. A total con job, playing the Fake News Media for Fools (but they know it)!"

Does that sound to be a statement of fact, an opinion or a rhetorical hyperbole?  Do you think reasonable people would disagree about the answer to that question?

The judge also found that Daniels failed to show that Trump "acted with actual malice or reckless disregard for the truth," which is ironic since Trump is famous for having reckless disregard for the truth.

NPR has more about the court's ruling here.  Politico has more here.

Court dismisses Sarah Palin's defamation claim against the New York Times

Back in June, the New York Times published an editorial that stated, among other things that "In 2011, when Jared Lee Loughner opened fire in a supermarket parking lot, grievously wounding Representative Gabby Giffords and killing six people, including a 9-year-old girl, the link to political incitement was clear. Before the shooting, Sarah Palin's political action committee circulated a map of targeted electoral districts that put Ms. Giffords and 19 other Democrats under stylized cross hairs."   At some point later, the newspaper published several corrections related to the op-ed piece, and Palin sued for defamation.

In order to support the claim, Palin would have to show that the statements are false, and, more importantly, because she is a public figure, she would have to prove "actual malice" on the part of the defendant, which means she would have to show the defendant acted with knowledge of falsity or reckless disregard for the truth."  This is a very difficult standard to meet and last week the court decided she would be unable to do so and dismissed the claim.

As one comment on the decision put it, "[a]n examination of the run-up to the publication of the erroneous op-ed showed there was no actual malice in the New York Times' assertions -- just some really bad op-edmanship. The statements were provably false, which is key to defamation claims, but there also has to actual malice." 

You can read the judge's order here.   It provides a relatively short discussion of the basic elements of a defamation claim including the requirement that the statement be "of and concerning" the plaintiff, a mention of the group libel doctrine, a discussion of how to distinguish between fact (actionable) and opinion (not actionable), and the issue of actual malice.

For more on the story go to:  NPR, the ABA Journal online and TechDirt.

Podcast on Georgia case regarding parents liability for negligence in handling child's use of social media

A few days ago, I reported on a recent case in which the Georgia Appellate Court held that parents could be held liable for failing to supervise their children use of social media, or perhaps more importantly, for failing to act to remedy the consequences of the use of social media.  The case is interesting in its own right, but it was made more interesting because it was quickly misinterpreted, as I explained in my previous post.

The case also generated some attention because it was reported that it was the first case in which a court imposed a duty on parents to supervise a child's computer use.  Today, Bloomberg Law posted a podcast on the case that you can listen to here.  Among other things, one of the panelists explains how the case is not really creating new law as much as applying old principles to a new type of scenario.

Wall Street Journal mistakenly reports that Georgia Court held parents can be liable for conduct of their children

Last week, the Wall Street Journal law blog published a story titled "Parents May Be Liable for What Their Kids Post on Facebook, Court Rules" in which it stated "Parents can be held liable for what their kids post on Facebook, a Georgia appellate court ruled in a decision that lawyers said marked a legal precedent on the issue of parental responsibility over their children’s online activity."  The story was then picked up and repeated by Smithsonian, and The Legal Satyricon (which criticizes the decision as incorrect because it failed to consider a certain federal statute).

The case is interesting but the problem is that the headline of the reported story is wrong.  The court did not hold that parents can be held liable for their children's conduct; the court held the parents can only be held liable for their own conduct.  That is a big difference.

As the court explains in its opinion, "liability for the tort of a minor child is not imputed to the child’s parents merely on the basis of the parent-child relationship." In other words, there is no vicarious liability for the tort of a minor. However, as the court continues, "[p]arents may be held directly liable . . . for their own negligence in failing to supervise or control their child with regard to conduct which poses an unreasonable risk of harming others," a duty which extends to those plaintiffs whose harm is foreseeable.

In the case, called Boston v. Athearn which is available here. a boy (Dustin, age 13) and a girl agreed to have some fun at the plaintiff's expense.  Using some information obtained by the girl, Dustin created a fake Facebook page in the plaintiff's name where they posted racist, sexually graphic, offensive and false information including posts that suggested the plaintiff was a homosexual and a racist, that she took illegal drugs and that she was on medication for mental health disorders.

About six days after the Facebook page was created, the principal of the school had determined who had done it and imposed discipline.  As a result, the culprit's parents were informed in detail of the children's conduct.  Dustin's parents claimed they disciplined him, but made no effort to access the Facebook page or to delete it.  The page remained available for almost a year.

In response to a motion for summary judgment filed by Dustin's parents, the plaintiffs argued that there were questions of material fact regarding whether the defendants were negligent in failing to compel Dustin to remove the Facebook page once they were notified of its existence and the court agreed.

Again, let's reiterate that the issue here is not whether a parent should be held liable for the conduct of a child.  The issue is whether the court should impose liability for the parent's own conduct.  More to the point, whether the court should impose a duty on the parents to do something more than what they did.

Because this is not a case where the court is trying to impose a particular parenting style nor passing value judgment on parental decisions on how to raise a child, the case is simple.  The parents have a duty to act like a reasonable prudent person under the circumstances and, given the facts, reasonable people can disagree as to whether they did.  I am not even sure we need more facts to decide the question.   Let it go to the jury and let them decide.

Court of Appeals holds that defamation plaintiff must show negligence (at least) in order to recover against blogger

A few days ago, the Court of Appeals for the Ninth Circuit decided an important new case on defamation.  The court held that Gertz v. Robert Welch, Inc., 418 U.S. 323, 350 (1974) (holding that the First Amendment requires non public figure plaintiffs in defamation cases to meet at least a “negligence standard”), is not limited to cases with institutional media defendants. Thus, the court held that the district court should have instructed the jury that it could not find the defendant blogger liable for defamation unless it found that she acted negligently.  The case is Obsidian Finance Group, LLC v. Crystal Cox, and the opinion is available here.

 As reported by the First Amendment Center: "In a landmark decision on Friday, a federal appellate court held for the first time that blogs enjoy the same First Amendment protection from libel suits as traditional news media. ... While the Supreme Court has previously observed that the lines between traditional news media and native web content have become blurred, this makes the first time that federal appellate court has essentially said that journalists and bloggers are one and the same when it comes to the First Amendment."  For more on the case go here.

England and Wales Reform Libel Laws

As reported in the Silha Center for the Study of Media Ethics and Law:  The Defamation Act 2013, approved by the British Parliament on April 25, 2013, just recently went into effect. The Act incorporates several key reforms into the British libel system which historically has favored plaintiffs.

The 2013 Act maintains the traditional premise of British libel law that the defendant bears the burden of proof, but section 1 of the 2013 Act requires plaintiffs to prove that a statement caused “serious harm” to their reputation for the statement to be considered defamatory. For-profit corporations must now prove “serious financial loss” to meet the serious harm standard. The Act also strengthens the defenses of truth and opinion. Section 2 of the Act creates a defense “for the defendant to show that the imputation conveyed by the statement complained of is substantially true.” Section 3 of the Act protects statements of opinion, provided that “an honest person could have held the opinion on the basis of … any fact which existed at the time the statement complained of was published.” Opinions are further protected as “privileged statements” if they appear in a publication of public interest, in a peer-reviewed scientific or academic journal, or if the defendant reasonably believed that the statement was in the public interest.

The Silha Bulletin has a detailed discussion of the new reforms here.