Florida Star v. B.J.F. case brief

Florida Star v. B.J.F. case brief summary
491 U.S. 524 (1989)

CASE SYNOPSIS

Appellant newspaper sought review of a judgment from the District Court of Appeal of Florida, First District, which affirmed the judgment in favor of appellee rape victim on the victim's invasion of privacy suit against the newspaper after the newspaper violated Fla. Stat. Ann. § 794.03 (1987) by publishing her name in its crime section. The newspaper alleged that § 794.03 Violated U.S. Constitutional Amendment I.

CASE FACTS
A police department prepared a report of a rape that contained the victim's full name and placed the report in its pressroom to which a newspaper was allowed unrestricted access. The newspaper printed an article on the rape derived entirely from the report and included the victim's name. The victim sued the newspaper for violating Fla. Stat. Ann. § 794.03(1987) which prohibited instruments of mass communication from publishing the names of rape victims. The trial court entered judgment in favor of the victim, the appellate court affirmed, and the state supreme court declined to hear the case.


DISCUSSION

• On appeal, the court reversed and held as follows: Whether the victim's right to privacy outweighed the newspaper's U.S. Constitutional Amendment I free press right had to be determined on the facts of the case. 
• The newspaper lawfully obtained the victim's name from a government source and had the right to assume that it was lawful to publish the name, and the crime reporting was a matter of public significance. 
• Thus, the newspaper could not be liable under Fla. Stat. Ann. § 794.03 (1987) without violating its Amendment I rights, although in a different case, the results might be different.

CONCLUSION

The court reversed a judgment in favor of a rape victim on the victim's invasion of privacy suit against a newspaper after the newspaper violation a Florida law by publishing the victim's name in its crime section.