Media essays

Can the media affect an individual's right to a fair and unbiased trial?

by Ceri Clarke

(2003)

Introduction
You wake to the usual crackle of your clock radio reporting today’s news and are advised that a well known Church priest is a known paedophile. As you continue your day, you consume constant media attention on the story – on the television, in newspapers, on the internet. The media reports continue to headline throughout the week, with the issue explored further as the media attempts to attack the subject from every possible angle. As the months pass the issue fades, but the media’s ability to adopt what was largely a myth and snowball it into a national catastrophe was as frightening as the real thing.
One day a letter arrives at your house. You are summoned to appear for jury duty. With no reasonable excuse, you appear to perform your civic duty. After a long day of waiting, you are eventually empanelled as one of twelve jurors in a paedophilia trial.
What has been the effect of "media overkill" on your perception of the defendant? Do you hold an unfair bias? Or have you reached a premature conclusion without even hearing the facts?
As the trial begins, the defendant is identified to the jury as the Church priest, whom had first become known to you months earlier.
Are you likely to have an anti-defendant bias due to the media reports?
The media has the ability to flood the public domain with information of an event which can easily prejudice the fair and unbiased criminal or civil trial of an individual by influencing potential jurors, or witnesses to an event.
Over the past 10 years, nearly 63% of American newspapers have been forced to defend themselves against charges of contempt for such "infotainment". But where the courts will remain the state agencies empowered to determine and enforce legal rights and liabilities, the media often appears in the public mind to be the ‘true’ dispensers of law and justice.
Is the mass-reporting of unique or special events, the very definition of "news", irresponsible journalism? Should the courts take steps to curb the potential effect prejudicial publicity has?
Pre-trial media
"…one of the effects was to potentiate interference with the administration of justice insofar as it was likely to provide a link within the memories of persons forming the jury…" AG NSW v Fairfax [1999] NSWSC 318, Barr J at 133
The fundamental philosophy of our adversarial justice system is that an individual is innocent until proven guilty. The issue as to the media’s effect on this can be traced back to 1961, where the American Supreme Court delivered a groundbreaking conviction solely on the basis of prejudicial publicity in Irvin v Dowd. Once precedent was set, a flow of cases were seen to pass through the American system.
The debates as to what constitutes contempt, however, first emerged in the Australian High Court in 1912, with the principles applied in that case remaining precedent even today.
In Australia, however, very few publications have been brought before the courts in regards to contempt. In Victoria, court rulings due to prejudicial publicity are rare.
The ethics of media reporting in Australia can be contrasted to America where a recent study indicated that 19% of defendants described in crime stories were associated with at least one category of potentially prejudicial information, as defined by the American Bar Association (Dixon and Linz, 2002).
Current Victorian Courts Information Officer and previous court-reporter for The Age, Ms. Prue Innes, describes Victoria as having a fair system which reasonably balances the media’s interests to publish with the requirements of a fair trial.
"In Australia, the timing of reports is a rough dividing line between what is appropriate media reporting and what is not," said Innes.
"The closer the trial, the more careful the media needs to be. But basically, once the risk of influencing juries or witnesses is over, restrictions on reporting material not presented to the jury no longer apply."
A recent example was seen in the recent Wales-King murders, commonly referred to as "The Society Murders". The case involved Matthew Wales who killed his wealthy mother and step-father after poisoning their food and then beating them with a plank of wood. The Age published an in-depth report into the investigation and court trial after Wales had been sentenced for the murders. The publication of such a report prior to trial would have been highly prejudicial, but its print after sentencing was a reflection of professional journalism.
"I prefer our system to that in the US where the interpretation of First Amendment rights mean the media are free to report more or less what they like, but courts have to take far more protective measures, such as sealing files or excluding the media from courts at times," says Innes.
Although few trials are effected by media reports, such prejudicial publicity is likely to cause harm to the judicial system itself. The public perceive that the media they consume is true. Media which conflicts with findings or outcomes of courts, therefore, can reduce confidence in the system, and may even influence future jurors to make radical decisions in an attempt to adopt society’s views.
What are the rules of reporting?
It is essentially the journalist’s responsibility to abide according to the law. However, the fact that most reporters are not trained in the law, and the editorial pressures to meet criteria for ‘newsworthy’, are considered to be reasons for prejudicial material slipping into the media mainstream.
Minter Ellison, one of Australia’s prominent media law firms, has developed a reporter’s guide to the law. The firm advises that information which should not be published includes:
- The criminal record of the accused
- Unfavourable comments on the character of the accused
- A photograph of the accused at a time when identification is a potential issue at the trial
- A pre-trial confession; or assertion of guilt or innocence of an accused
- Results of a private investigations by the media of a crime, pending trial
- A discussion of the merits of the trial or its likely outcome
- Publications which may affect witnesses or potential witnesses or the evaluation by the jury of the evidence
- Evidence prior to trial
- Interviews with jurors
In Victoria, only a minority of journalists have stepped beyond such guidelines. An example being Derryn Hinch in 1986, where on three occasions he broadcasted particulars of an accused man’s prior conviction and of two prior charges, despite being warned after the second broadcast that contempt proceedings might be instigated against him. The court convicted and sentenced him to six weeks imprisonment for the third broadcast and a fine for the previous two. Due to Hinch’s position in the media, it was held that his broadcasts were "recklessly" prejudice as in the normal course of a criminal trial, these facts would be withheld from a jury to promote ‘presumption of innocence’.
More recently, the Hamilton Spectator newspaper was found guilty by the Victorian Supreme Court of contempt after publishing submissions heard in the absence of the jury. The story, written by an inexperienced journalist, was seen as negligent journalism which had a potentially prejudicial affect on the trial of an accused.
In regards to the dangers of photographs, Who Weekly magazine were fined $100,000 after publishing a photograph of Ivan Milat ("Backpacker murders") at a time when identification was an issue.
The law of contempt
"[It] would be a disgraceful thing if "trial by newspaper" were allowed to supersede, or to influence, the ordinary process of the courts."
John Fairfax and Sons Pty Ltd v McRae (1995) 93 CLR 351
The ‘law of contempt’, a term with heavy ideological overtones, is the phrase which has been developed by courts to describe a wide range of conduct involving some element of affront or resistance to the authority of the courts, or some degree of interference with the administration of justice by the courts.
The law operates to prevent the public denigration of courts and judges, and it may affect the publication of accounts of jury deliberations.
The Court may consider a number of factors in order to determine whether a publication amounts to contempt, such as:
- the nature and extent of the publication,
- the nature of the proceedings said to have been prejudicial including whether they are proceedings before a jury, and
- the time which elapses between publication and trial.

Rules and Defences
"[C]reating an extremely hostile feeling against him or her in the minds of witnesses and potential jurors, cannot be excused…"
AG v Hinch and Macqaurie Broadcasting Holdings Ltd (1937) 37 SR (NSW) 242
There are three major strands of liability within contempt law:
1. The law of scandalising: the tendency to undermine public confidence in the administration of justice;
2. The sub-justice rule: Where a publication has a real and definite tendency to prejudice a current or forthcoming trial, by virtue of exerting influence on the deliberations of the person(s) responsible for adjudicating the issues at stake; and
3. The prejudgement principle: although the report does not influence the outcome of particular proceedings or undermine public confidence in the administration of justice, it nonetheless prejudges issues at stake in a current or forthcoming trial.
The second strand, the sub-justice rule, is of major significance as this affects the day-to-day operations of media production.
There are two defences to the sub-justice rule:
1. Fair, accurate and contemporaneous; and
2. ‘Public interest’, that is, the effect of prejudicial material contained in a discussion of matters of general public interest which bears only indirectly and unintentionally upon a current or forthcoming trial.
Interestingly, the majority of the High Court held that it is not contempt if a report involves a case where no proceedings are pending before a court, albeit such circumstances could amount to defamation.
Ignorance of the law; not having the realisation that one is committing a contempt; or, not having the intention to be of contempt are not defences.
The public interest defence: the loophole for prejudicial media?
"A publication specifically directed … to have a prejudicial effect on the fair trial of the individual … cannot be excused by pleading that it is a matter of public interest." Murphy J, AG v Hinch and Macqaurie (1937) 37 SR (NSW) 242
In John Fairfax Publications, Barr J delivered a surprising outcome in light of the High Court’s 50 year reluctance to disallow the public interest defence. Despite finding that one of the effects of the prejudicial report was to interfere with the administration of justice, he stated:
"It is reasonably open to say that the detriment to the trial was outweighed by the public interest [on the issue of drugs] in the freedom of communication." (at 134)
The result of Barr J’s decision, and a somewhat troubling outcome from a legal viewpoint, is that a broad opportunity now exists for the sophisticated journalist in almost any situation to publish highly prejudicial material which has the tendency to interfere with the administration of justice, so long as the material is constructed to appear to deal with broad issues of public concern and interest, of which the accused person’s involvement is only an aspect of a general issue or problem.
The coverage of Ivan Milat (backpacker murders) and Martyn Bryant (Port Arthur mass-murder) can be taken as examples. Both had been convicted prior to the 1999 Fairfax judgment. On current law the media may argue that they were merely highlighting "broad issues of public concern and interest" (Barr J) in regards to the dangers of hitchhiking or backpacking in regards to Milat, and discussing the issue of gun control when reporting on Bryant. This is in despite that extensive pre-trial publicity had left people with no doubt that the two men had committed the murders for which they were charged.
More currently, the eagerness of the media to act as investigators rather than informers, as they attempted to piece together the "Society Murders" disappearance, was potentially prejudicial to the trial of Matthew Wales who was publicly identified as the killer. Although argued as a case of public interest, it would be likely that some action would have been taken had he not pled guilty to the charges.
Jury members – is the media a prejudicial influence?
When introduced into England by the Norman Conquerors in 1066, the jury was primarily an administrative tool used in areas of Europe controlled by the Carlovingian kings. The jury was seen as a source of information as to local facts and events.
The moving force to further develop the role of the jury was Henry II, who made provision for a litigant to ask for a royal writ summoning a jury to decide the issue when a title to land was in dispute.
So entered the jury into the sphere of the civil law, thus planting the seed that developed into its present form.
Today, trial by jury is considered a cornerstone of our temple of justice. A group of ordinary people who represent the power of the people against the power of a potentially oppressive state, and who swear to fairly determine an issue of fact.
The current relevance of juries is questionable, with their use rapidly declining in Victorian courts. A major cause of the decline is the unpredictability of juries, especially in complex or highly emotive cases, which has raised concerns that the facts or issues jurors are considering, and what they are supposed to be considering, may be two entirely different things.

Research
The obvious limitation to researching topics involving juries is the mystery of the process in which they conduct deliberations. A deliberative, judicially protected, secretive process that prevents anyone from observing discussions behind the closed doors of the jury room.
In Victoria, the jury is legislatively protected by the Juries Act 2000, which prohibits any person questioning or even approaching jurors.
A damaging blow to research being accepted as evidence was delivered by Barr J in John Fairfax Publications Pty Ltd. Professor Neil Vidmar, working for Fairfax, formulated a research for the High Court case that investigated the memory and recall of potential jurors who had read potentially defamatory newspaper article(s). Unfortunately, the research was plagued with limitations, however the evidence was not accepted on grounds that "he did not adequately factor into his analyses the distinctive environment of the courtroom" (Barr J). An obstacle that would appear impossible to conquer.
In light of limitations, researchers have used surveys and simulation studies in an attempt to gain information. The studies are predominantly American.
"Pretrial Publicity" by Kramer, Kerr, and Carroll in 1990 found that when mock jurors were exposed to emotional or factual publicity, its effects were only evaded after a delay between exposure to pretrial publicity and consideration of evidence.
This result was echoed by Jones J in the recent Victorian case of Michael Radd. His honour postponed the trial for four months to allow prejudicial publicity time to abate as to reduce the likelihood of such prejudicing jurors. The case is a rare example in this state where prejudicial media has been seen to directly effect a trial.
Moran & Cutler (1991) discovered that exposure to pretrial publicity was significantly correlated with perceived culpability of the defendant, but exposure to pretrial publicity was not correlated with willingness to admit partiality. This finding is troubling as it suggests traditional efforts to curb the effects of pretrial publicity may not effectively reduce bias.
In 1993, Riedel found that prejudicial pretrial publicity led to longer sentences in a mock trial about rape, whereas non-prejudicial pretrial publicity led to shorter sentences. This finding is supported by the concern of Mr Robert Richter, QC, who told the County Court this May that his client, Aboriginal leader Geoff Clark, would not receive a fair trial due to the massive amount of publicity generated by the case. Clark faces a civil court trial on rape allegations. Although a sentence would not be imposed on Clark, the research suggests a jury would be more likely to deliver a harsher judgment in the light of the publicity.
"Impact of Pre-trial Publicity" by Ogloff & Vidmar (1994) investigated the effect of pre-trial publicity on the decision making of jurors. The study focussed on an actual case that had gained extensive pre-trial publicity. Their survey revealed 91% of respondents, all of which were potential jurors, had watched the case on television and 79% had read about the case in newspapers. This exposure, it was found, produced an anti-defendant bias in the subjects and that television exposure increased the intensity of this bias.
Bruschke and Loges (1999) found that moderate publicity was more influential than high or low publicity in biasing juries, but that publicity in general had little effect on judicial outcomes. However, this study may suffer from a number of methodological shortcomings, including a lack of attention given to prejudicial newspaper content.
Australian studies have only recently appeared. The Vidmar (1999) research for Fairfax is one such example. Although riddled with limitations and thus not excepted as evidence, the research concluded that the subject newspaper article was unlikely to be prejudicial.
Most recent of studies is, "Managing Prejudicial Publicity", by Chesterman, Chan & Hampton (2001) published by the Law and Justice Foundation of New South Wales. The empirical study of criminal trials in NSW concludes that criminal juries have a relatively successful record of resistance to publicity. The study is unique in that the researchers were granted interviews with jurors with the prior authorisation of the Attorney General under the Jury Act 1977. The identities of jurors were not disclosed. A significant finding was that in 40% of trials covered, the verdict was delivered despite media publicity urging or suggesting a different outcome. In 75% of the trials, the judge and both counsel thought the outcome to be justified. In 7.5% of the trials, it was found that the verdict was likely to have been significantly influenced by publicity rather than based on evidence.
The study found that juror recall of prejudicial publicity was more likely when:
(a) the accused was independently well known in the community (e.g. Aboriginal leader Geoff Clark);
(b) the alleged offence occurred in the area where the juror lived (e.g. such concerns were voiced in the trial of Martyn Bryant, who committed the Port Arthur mass-murder); or
(c) the jurors did not encounter it until after the trial began (e.g. such prejudicial conduct by The Age led to the Supreme Court case, R v David Syme and Co Ltd, in 1982. The article in The Age, although not directly referring to the case, was seen likely or calculated or had a tendency to prejudice the trial of the Zampaglione brothers – who were at that time facing a drug trial – by influencing members of the jury who were not ‘locked-in’ during the trial).
The study identified the Internet as an emerging threat to fair trials, with some members admitting to obtaining prejudicial information from a website without the judge or counsel realising they had done so.
The findings of the above research all conclude that the media has the ability to prejudice. This, it may seem, is obvious. The research also indicates that Australia has a significantly successful record at restricting such publicity from interfering with jury trials, especially compared to America.
The findings are supported by Innes, who highlights that we rarely see action taken against the press like we see in America.
"The press are almost never locked out of courts. Our system is more transparent for that," she said.

Media’s method of collecting fact
The media’s method of collecting fact is not limited to attending courts. "Fact leaking" to the media has been identified as one potential prejudicial concern. An American study, Imrich (1995), found that of the 27% of defendants who were associated with prejudicial publicity, law enforcement officials and prosecuting attorneys were the most prevalent sources of such information. In Australia, we do not experience such barrages of prejudicial information, and in most cases reporting of such facts are not contemptuous. Reporters should not be used as an arm of law enforcement or as a "tool" for parties.
Consumer demand Vs Contempt
The plight to publish newsworthy content is a popular argument for the media. The community has a right to know of happenings within our justice system, and likewise it is important that the system remains somewhat transparent.
The wants of the community, however, can be separated from the needs of the community. Eventually, all the facts known by a journalist can be reported, but pending trial the courts are entitled to protect impartiality. It is irresponsible journalism to launch a deliberate campaign of vilification against a particular individual or party, designed to influence the minds of any person who may deal with the case, under such a fair framework.

Conclusion
The development of guidelines or rules, which permit proper access to the courts by the media, and ultimately the public, continue to be developed both domestically and internationally. But for now, we are surrounded by the problems of secrecy in such vital matters as jury proceedings, with Chesterman’s (2001) research an unique exception; excesses in reporting which lead to excessive judicial restraints; and a public that wants to know things, such as an individual’s past convictions, and a need to know about other things, such as procedural matters.
There is little doubt that the media can directly hamper an individual’s right to a fair and unbiased trial by influencing juror-stance on an issue. Brabin J, in Attorney-General v London Weekend Television, paralleled this viewpoint with television commercials, suggesting that although such advertising was ephemeral its impact could amount to contempt because of the impact it had. If it did not achieve this impact, he said, "television advertising would be very unrewarding".
So as you sit in your jury chair and listen to the opening of the prosecution’s case, there is little doubt that you have been prejudiced. Sure, the time lapse has evaded factual memory of the case, but the emotions you felt will stay with you forever.
But are we forgetting that media consumption is part of everyday life for the average citizen? Trials are powerful public events, and a fundamental part of the democratic process. The quest to find a member of society who has not consumed some form of prejudicial media would be so removed from society that they could hardly be recognised as one’s peer on a jury. A restriction imposed by courts on the media, it is argued, only undervalues the responsibility exercised by most jurors when hearing cases, for it is from ordinary people which alleged prejudicial material is withheld.
The Australian research findings indicate that the steps currently being taken by media organisations, and state judiciary, to reduce the effects of prejudicial media – stemming from irresponsible journalism – in the public sphere from interfering with trials are proving to be effective. The media has the opportunity to influence, but at current it seems the pride of professionalism, education, or maybe the risk of harsh punishment restrains the urge to step beyond the boundaries of fairness.
According to Chesterman’s recent study, despite being exposed to prejudicial bias, as a jury member you are more concerned with acting on the facts rather than the publicity you consumed. The priest’s right to a fair and unbiased trial, therefore, rests on this finding being reflected by each individual on the jury.
.
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