Seattle Times Co. v. Rhinehart
SCOTUS - 1984 (467 U.S. 20)
- Rhinehart (P) is spiritual leader of a weird religious sect. Seattle Times (D) wrote several articles about him and his group.
- P alleged that D's articles were untrue and caused harm. P sued D for defamation and invasion of privacy (asked for $14M).
- D asked in discovery for a list of donors and for a membership list.
- The trial court initially granted the request and denied a protective order. Later, the court issued a protective order over the information.
- Both parties appealed. P didn't want to turn info over; D wanted to be able to publish.
- Lower court compelled discovery and issued a protective order.
- WA Supreme Court affirmed.
- SCOTUS affirmed, compelled discovery and issued protective order.
- Do parties in civil litigation have a First Amendment right to disseminate, in advance of trial, information gained through the pretrial discovery process?
- The First Amendment is not offended by the restriction of dissemination of information gathered in pretrial discovery if a protective order is issued upon showing good cause as required by Rule 26(c). Also, a party can disseminate the information if it is obtained from other sources besides discovery.
- Although there is public interest in knowing more about the P, it does not follow that the D has an unrestrained right to disseminate information that has been obtained through pretrial discovery.
- D only gained the information they want to disseminate through the virtue of the trial court's discovery processes.
- A party has no First Amendment right of access to information made available only for purposes of trying his suit.
- Pretrial depositions and interrogatories are not public components of a civil trial.
- The party may disseminate the identical information covered by the protective order as long as the information is gained through means independent of the court's processes.
- Courts have a substantial interest in preventing abuse of its processes (discovery). It is possible for a party to obtain info that not only is irrelevant but could harm the reputation and privacy of the opposing party.
- None given.
- SCOTUS says the trial court should review discovery processes for abuse of discretion.