N.C. cyberbullying statute is unconstitutional – N.C. Supreme Court

1,745 Comments / By / June 14, 2016 / North Carolina Supreme Court

State v. Bishop. According to a North Carolina Supreme Court opinion handed down last week, the state’s anti-cyberbullying statute is unconstitutional under the First Amendment.

N.C.G.S. § 14-458.1 makes it “unlawful for any person to use a computer or computer network to . . . [p]ost or encourage others to post on the Internet private, personal, or sexual information pertaining to a minor” “[w]ith the intent to intimidate or torment a minor.”

The threshold issue before the Court was whether the statute criminalizes conduct or speech. If you are a follower of First Amendment cases, this is a familiar issue. If the statute criminalizes conduct, not speech, the degree of scrutiny the statute faces is much lower.

The opinion concludes that the statute at issue prohibits speech:

Against this blurred doctrinal landscape, the line is not always bright between what is protected by the First Amendment and what is not. Here, however, we are satisfied that N.C.G.S. § 14-458.1(a)(1)(d) applies to speech and not solely, or even predominantly, to nonexpressive conduct.

. . .

As the United States Supreme Court has made clear, the protections of the First Amendment extend in full not just to the Internet, but to all new media and forms of communication that progress might make available. Accordingly, we conclude that N.C.G.S. § 14-458.1(a)(1)(d) of North Carolina’s cyberbullying statute implicates the First Amendment because that provision restricts speech and not merely conduct.

[Citations omitted].

Then, relying on Reed v. Town of Gilbert, ___ U.S. ___, ___, 135 S. Ct. 2218, 2226 (2015), the opinion further concludes that the statute is content-based. The plain language of the statute regulates certain speech based on particular subject matter. Because the statute criminalizes some messages but not others, it is content based.

Statutes that regulate speech based on content are subject to strict scrutiny – they must be narrowly tailored  to serve a compelling government interest.

There was no dispute that protecting children from online bullying is a compelling government interest. To show that the statute is narrowly tailored to that interest, the state has to show that the statute is the least restrictive means of addressing the issue.

The opinion analyzes the statute and decides that, for a number of reasons, the state has not met this burden. First, the statute contains no injury or awareness requirement. Second, the intent requirement – which prohibits the intent to “torment” – is too broad, according to the Court. Protection of minor’ mental well-being is a compelling interest, but protecting them from annoyance is less clear. Third, the undefined terms of “private,” “personal” and “sexual” are vague enough that a prohibition on “personal” information would “essentially criminalize posting any information about any specific minor if done with the requisite intent.” [Emphasis in opinon]. Finally, the mens rea requirement brings no clarity to the statute.

In sum, however laudable the State’s interest in protecting minors from the dangers of online bullying may be, North Carolina’s cyberbullying statute “create[s] a criminal prohibition of alarming breadth.” Even under the State’s interpretation of N.C.G.S. § 14-458.1, the statute prohibits a wide range of online speech—whether on subjects of merely puerile interest or on matters of public importance—and all with no requirement that anyone suffer any actual injury. In general, “[i]t is rare that a regulation restricting speech because of its content will ever be permissible.” Certainly, N.C.G.S. § 14-458.1(a)(1)(d) of the cyberbullying statute is not.

[Citations omitted]

 

Brandon J. Huffman

Brandon is the founder of Odin Law and Media. His law practice focuses on transactions and video games, digital media, entertainment and internet related issues. He serves as general counsel to the International Game Developers Association and is an active member of many bar associations and community organizations. He can be reached at brandon at odin law dot com.

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    Understanding COSC Certification and Its Importance in Watchmaking
    COSC Certification and its Strict Standards
    Controle Officiel Suisse des Chronometres, or the Official Swiss Chronometer Testing Agency, is the official Swiss testing agency that verifies the accuracy and precision of wristwatches. COSC accreditation is a mark of quality craftsmanship and dependability in chronometry. Not all watch brands seek COSC accreditation, such as Hublot, which instead sticks to its proprietary strict criteria with mechanisms like the UNICO, attaining comparable precision.

    The Art of Exact Chronometry
    The core system of a mechanized timepiece involves the spring, which provides energy as it loosens. This mechanism, however, can be vulnerable to environmental elements that may impact its precision. COSC-accredited mechanisms undergo demanding testing—over fifteen days in various circumstances (5 positions, three temperatures)—to ensure their resilience and dependability. The tests evaluate:

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    Historic Background and the Development of Timepieces
    The notion of the timepiece originates back to the requirement for exact timekeeping for navigational at sea, highlighted by John Harrison’s work in the 18th century. Since the official establishment of COSC in 1973, the validation has become a standard for evaluating the accuracy of high-end timepieces, maintaining a tradition of excellence in horology.

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