Americans have the benefit of the SPEECH Act which makes foreign libel judgments unenforceable in the US if the verdict isn’t compliant with the First Amendment. Musk is probably safe but JK Rowling is in some serious trouble because British libel laws are skewed heavily in favor of plaintiffs.
Its not a libel case actually, its a criminal proceeding that could (or could not) lead to prosecution for cyberbuling, which is a type of penal infraction in France. But from what I know of American law (granted, I know more about other systems), the USA tends to also protect its citizens from other types of judgments as well, and like the majority of western countries, it doesn’t extradite its nationals. I believe the UK is the same way.
You are correct in regards to British Libel laws, but I don’t actually believe this is all that relevant in this case since… its not a libel case, and it wasn’t filed in the UK.
Americans have the benefit of the SPEECH Act which makes foreign libel judgments unenforceable in the US if the verdict isn’t compliant with the First Amendment. Musk is probably safe but JK Rowling is in some serious trouble because British libel laws are skewed heavily in favor of plaintiffs.
Its not a libel case actually, its a criminal proceeding that could (or could not) lead to prosecution for cyberbuling, which is a type of penal infraction in France. But from what I know of American law (granted, I know more about other systems), the USA tends to also protect its citizens from other types of judgments as well, and like the majority of western countries, it doesn’t extradite its nationals. I believe the UK is the same way.
You are correct in regards to British Libel laws, but I don’t actually believe this is all that relevant in this case since… its not a libel case, and it wasn’t filed in the UK.