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Judges Rule Raped Woman Can Sue 'Enabling' Web Site (vice.com) 383

Web sites that matched models to photographers also led dozens of women to a pair of rapists in 2011, according to Vice. "Civil court documents show that the owners of Model Mayhem knew about the first wave of rapes but failed to issue a warning to users," Vice reported last summer. Facebook, Craigslist, and Tumblr filed briefs in support of the "Model Mayhem" site, arguing that allowing women to sue them could create a new "failure to warn" liability for other web sites. But now AmiMoJo writes:In a decision that one day could have reverberations across the internet, a three-judge panel in California decided she can sue the Model Mayhem site that the pair used to lure their victims. "Congress has not provided an all purpose get-out-of-jail-free card for businesses that publish user content on the Internet," Judge Richard Clifton wrote in the panel's decision. The CDA traditionally exempts web sites from liability for anything their users post. Do Slashdot readers think there should ever be any exceptions?
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Judges Rule Raped Woman Can Sue 'Enabling' Web Site

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  • by drinkypoo ( 153816 ) <drink@hyperlogos.org> on Saturday June 04, 2016 @06:34PM (#52250347) Homepage Journal

    If they had specific knowledge that crimes had been committed, and who committed them, then they may have been aiding the criminal activity. If someone had suggested to them that something like that might have been going on, but gave no specifics whatsoever, then not so much. Either way, a court and probably a jury will have to decide.

    • by DRJlaw ( 946416 ) on Saturday June 04, 2016 @07:11PM (#52250497)

      If they had specific knowledge that crimes had been committed, and who committed them, then they may have been aiding the criminal activity. If someone had suggested to them that something like that might have been going on, but gave no specifics whatsoever, then not so much.

      No. That is not the standard. This [west.net] is:

      DUTY OF CARE OF PROPRIETOR OF BUSINESS
      The proprietor of a business establishment owes a duty of care to customers when they come upon the business premises at the proprietor's express or implied invitation. This duty of care requires the proprietor to exercise reasonable care to discover whether accidental, negligent or intentionally harmful acts of third persons are occurring or are likely to occur on the business premises. If a proprietor knows, or should know that such acts are occurring or are likely to occur, the proprietor has the further duty to either give the customer a warning adequate to enable the visitor to avoid the harm, or otherwise to protect the visitor against such harm.

      This has nothing to do with aiding the criminal activity. This has very little to do with whether they had specific knowledge of crimes. This has to do with whether they invested reasonable effort into determining whether a risk was likely to be present, and warned their customers of the risk. If someone suggest that something like that might have been going on, then for various values of might (with a threshold between more likely than not and lottery odds), they very well could be liable.

      • Re: (Score:2, Insightful)

        And wouldn't they have the same duty of care to protect their clients from false claims. I'm not saying that in this case the claims were false or not because I didn't read the article but it would be easy for a model who had a disagreement with a photographer to bring up a false charge to the site in order to hurt the photographers business.

        There is something that used to matter and that is the presumption of innocence.

        • by Marful ( 861873 )

          And wouldn't they have the same duty of care to protect their clients from false claims.

          I would argue yes. However, to determine the credulity of the allegations would require some form of due diligence in looking into said claims.

          Did Model Mayhem do such? I don't know, but that to me is the question that potentially opens up Model Mayhem to liability.

          If they did no such due diligence, then regardless of which position you take, they failed in their duty.

          • by Mal-2 ( 675116 )

            You can't be raped on a website. The only responsibility would be a warning that anyone you meet online might not be who they represent themselves to be, and that meeting them in person must take place at your own risk. This could be buried in the terms and conditions, because the users all confirmed that they read them cover to cover when they signed on -- although nobody did, of course.

            • If you aren't GO AWAY

              If you are an adult, we assume you are capable of intelligence and realise that it is YOUR responsibility to worry about who you may meet via this website.

              The fact that we have to include this clause is evidence that our society deserves its status as a bad joke in the rest of the world.

      • by iCEBaLM ( 34905 )

        A website isn't a premises. When I browse a website, I am not literally going to the destinations location. This law means the proprietor of a business has a duty of care to people visiting a physical location he owns and controls.

        • by DRJlaw ( 946416 ) on Saturday June 04, 2016 @08:43PM (#52250829)

          This law means the proprietor of a business has a duty of care to people visiting a physical location he owns and controls.

          The standard is not a statute. The standard comes from English (and then American) common law. A key aspect of the common law is that it evolves and adapts, frequently making use of analogies to prior circumstances to determine whether there are, for example, duties of care in new circumstances.

          If you think that the word "premesis" in a half page summary of a common law concept going to be enough to completely shield this business from liability (i.e., a jury will not be permitted to decide whether there is a special relationship and duty to warn), then you either failed the first year of law school or never attempted to attend.

          • by iCEBaLM ( 34905 )

            The law you site was made to make sure that business owners put up warnings to unsuspecting customers if they have people doing potentially harmful work in their buildings, like renovators/construction, etc. This doesn't translate to a website. It's not reasonable to think that a certain person is going to commit rape, especially if you've never met them. It doesn't pass the foreseeability test, let alone the multi-factor test. Does eHarmony or PlentyOfFish have the same duty of care? Are we going to requir

      • I don't know. Are the owners of derelict buildings where drug selling and other crimes are openly conducted ever liable for that?

        • I don't know. Are the owners of derelict buildings where drug selling and other crimes are openly conducted ever liable for that?

          If they can be shown to know about it beforehand, yes. Then they're aiding and abetting criminal activity, and property used in the commission of a crime can be seized, and that explicitly applies to land in the case of drug busts. That's why the states generally want people to get permission from their landlords before e.g. they do a grow; then they can seize the property.

    • Exactly. As sickening as those two freaks are, in the absence of a conviction or any other kind of legally binding decision (e.g. a civil suit), for all Model Mayhem knew they were just allegations.

    • It's not so cut and dried or even the same crime or as simple as aiding criminal activity
      By making themselves look as much as possible like a professional modeling agency they deliberately lulled people into a false sense of security.
      So more like fraud than trafficking, but still a deliberate action that it's worth getting the courts to sort out.
    • by drolli ( 522659 )

      Also important:

      * did they state that the photographers were checked by them
      * did the website state a warning (some web sites interesting for potential abusers do)
      * what did the TOS say about whose obligation it is to do what?

      But I mean, seriously, the police knew one of the guys tried to get a 13yo to pose semi-nude while he worked there and they just fired him?

      I mean it's good that the judge allows to sue the website, but i for sure hope that the court will consider the fuckups of the police and possibly t

  • by Todd Knarr ( 15451 ) on Saturday June 04, 2016 @06:50PM (#52250399) Homepage

    The liability isn't being created by user-posted content in this case. It stems from the site actually knowing about the actions of some users and failing to give notice when it could foresee that that failure would put other users at risk. It's the same principle that says that if I know of a danger on my property and fail to post notice of it or take steps to keep people out I'm liable if someone gets hurt by it. Section 230 never comes into play.

    • by guruevi ( 827432 ) on Saturday June 04, 2016 @07:06PM (#52250473)

      Your example depends largely on your jurisdiction. Some have successfully allowed thieves to sue because they got injured breaking and entering, others allow you to beat or shoot to death anyone who appears on your lawn.

      The question is indeed whether they had knowledge that a convicted sex offender was using their site as bait or alternatively whether they had made a promise of background checks and legitimacy of all parties and failed to fulfill that promise . It's a tall order to prove that, if this is a craigslist type site for models, the assumption of risk should at all times remain with all parties involved. If I get murdered or raped because I wanted to buy a $15 lawn mower from CL, why would CL be liable? Do you hold a classic paper liable for the ads that appear? What if a magazine were to advertise a drug that later turned out to be harmful or even fraudulent, would you hold all advertising channels for homeopathic "cures" liable?

      • Yeah, Model Mayhem still isn't doing any background checks or any such things. I just signed up on the site on the "agent" side, and the only requirement to post a shoot was to give them some money.
  • by Sebby ( 238625 ) on Saturday June 04, 2016 @06:53PM (#52250409)

    Do Slashdot readers think there should ever be any exceptions?

    If the site(s) knew something, then yes, they should have some accountability. In this regard, it should be treated similarly as someone who had participated/facilitate, unknowingly or not, in money laundering - the law won't care about actual intent/claimed innocence, only about the facts.

    • If the site(s) knew something, then yes, they should have some accountability. In this regard, it should be treated similarly as someone who had participated/facilitate, unknowingly or not, in money laundering - the law won't care about actual intent/claimed innocence, only about the facts.

      That's what's being alleged in this case.

  • by 140Mandak262Jamuna ( 970587 ) on Saturday June 04, 2016 @07:05PM (#52250459) Journal
    If the website made money by the contents users posted, then they also have a liability. Allowing them to profit from the contents, but without any liability will create perverse incentives. There are enough provisions and protections for the websites already. If they did not know about the criminals misusing their site, it is one thing. If they knew about it and kept quiet to make money they are liable.

    But where to draw a line between rapists claiming to be photographers posting classified ads to lure people in? Or even simple job posting in your old dead tree newspaper to lure applicants in?

    We should draw the line on a case by case basis. Let them sue, let us look at the facts of the case and then decide whether they are culpable or not. Giving them blanket immunity without even looking at the facts of the case is simply wrong.

    • I think this is an interesting situation from a legal standpoint and worth thinking about. But your response makes more sense than anything else I read here.

      IMO, there should be an expectation that any web site providing a service for pay would make reasonable efforts not to allow misuse of the site to continue, especially when it's of a criminal nature and injuring your site's own users. When such things happen, they have to be examined on a case by case basis by the legal system. (EG. How much evidence re

    • I think they actually make most of their money by charging photographers, agents, etc to post job listings. As far as I can tell, most models are posting for free. There is some "premium membership" for models, which I'm assuming they charge for...but it seems like maybe 1% or less of their members go that route.
  • by rsilvergun ( 571051 ) on Saturday June 04, 2016 @07:10PM (#52250489)
    The site didn't know exactly who was doing it, but they knew someone was using their service to find victims and intentionally choose not to disclose the fact. The reason the judge let it go through is that there's evidence the company had knowledge of a specific risk and failed to alert the users. That's why common carrier protections didn't cause the case to be thrown out.

    Craigslist has the same issue, and as such they display warnings to users when you respond telling you about common scams.
  • by Crashmarik ( 635988 ) on Saturday June 04, 2016 @07:14PM (#52250509)

    Well I suppose the weekly world news is out of business so no more batboy or doctors resurrect Lincoln stories

    http://www.businessinsurance.c... [businessinsurance.com]

    Anyway there is an article from a source that is actually in the business of informing their readers.

    Lavont Flanders Jr. and Emerson Callum were using Model Mayhem to identify targets for a rape scheme, allegedly as early as 2006, according to the ruling. They browsed profiles on Model Mayhem posted by models, contacted potential victims with fake identities posing as talent scouts, and lured the victims to south Florida for bogus modeling auditions, according to the ruling. When a victim arrived, they used a date rape drug to put her in a semicatatonic state, raped her and recorded the activity on videotape for sale and distribution as pornography, according to the ruling.

    There's who, what and when, how, why. The firm is in Florida, the model from Brooklyn going to guess the attorney was shopping for the craziest jurisdiction he could find to get this to move forward.

    And here is the theory of liability

    Jane Doe's claim is different, however,” says the ruling. She does not seek to hold Internet Brands liable as a 'publisher or speaker' of content posted on the Model Mayhem website, or for Internet Brands' failure to remove content posted on the website. Flanders and Callum are not alleged to have posted anything themselves.”

    “Instead, Jane Doe attempts to hold Internet Brands liable for failing to warn her about how third parties targeted and lured victims through Model Mayhem” said the ruling.

    So three judges in California decided that not telling women that hooking up with strange men through the internet could be dangerous is sufficient to sue for negligence. Why not, we have to tell people plastic bags are not toys and pose a suffocation risk.,

    • It's worse case for Internet Brands than that. One of the allegations of the lawsuit is that Internet Brands knew about these guys, knew enough to warn their users, and actually sued the people they bought ModelMayhem from.

      From the opinion: "It is also alleged that Internet Brands sued the Waitts in August 2010 for failing to disclose the potential for civil suits arising from the activities of Flanders and Callum." It's also covered in the businessinsurance article you linked to.

      If you know enough to sue w

    • by AmiMoJo ( 196126 )

      Actually, the Vice article explains it better than your's does:

      Critical to understanding this caseâ"â"and what makes it different from, say, someone suing Craigslist after buying a bicycle off a classified ad and getting in a crash while riding itâ"â"is a legal concept called failure to warn. Callum and Flanders were arrested in 2010 for pulling a similar rape scheme with a handful of victims, but the case proved difficult to prosecute, and they were released. Doe is alleging that Model Mayhem, knowing they were on the loose, should have warned users not to fall for similar scams in the future.

      The key thing is that Model Mayhem were aware of the arrests (or so she claims, and it seems likely given that the police would almost certainly have contacted them) but didn't issue warnings. I expect it will come out that they decided not to email their users with some extremely negative publicity that might make them leave the site, putting their profit before the model's safety.

  • by bigtreeman ( 565428 ) <treecolin@nosPAm.gmail.com> on Saturday June 04, 2016 @07:36PM (#52250589)

    These girls went off and did stuff which was inherently risky without personally taking precautions.
    Wish I could get a payout for some of the stupid, risky stuff I've done through my lifetime.
    Some lawyer told her she can make lots of money suing the web site, so can the lawyer.

    • Comment removed based on user account deletion
  • by redelm ( 54142 ) on Saturday June 04, 2016 @07:38PM (#52250601) Homepage

    Liberty depends on not causing harm. Either accept reasonable restrictions or get none. Would you rather total strict liability? In this case, the website was willfuly negligent, potentially to the level of depraved indifference.

  • by Anonymous Coward on Saturday June 04, 2016 @07:58PM (#52250683)

    I'm a photographer, my fiance is a model who also runs a "watchdog" group about creepy/seedy people in the industry. In one instance, there was a convicted sex offender who other models apart of her group reported on about several instances where he was crossing the line. She reported his model mayhem profile to the site, along with the link to his conviction on a government website; and they treated her like shit, refused to take any action, removed her profile when she complained about how shitty and dense they were being. It wasn't until she publicly blogged about it, with screenshots of the email chain, that they started singing a different tune, and restored her profile and deleted the sex offenders.

    This was just last year. Not to mention the mysterious disappearances linked to the model mayhem site a year or two before that. Most models I have worked with have a creepy/rapey vibe story that starts with Model Mayhem. And by all accounts, they do not take any user reporting seriously.

    http://www.nydailynews.com/news/national/modeling-networking-site-common-denominator-disappearance-colorado-women-reports-article-1.1278375
    http://www.abc17news.com/news/modeling-website-linked-to-disappearances-rape-and-human-trafficking/20037496

    • by Anonymous Coward on Saturday June 04, 2016 @08:09PM (#52250719)

      Oh, and I forgot an important detail of the story. Before they acted on it, they threatened her with legal action if she did not take the blog post down. Claiming that posting the messages were in violation of their TOS. When she didn't budge on from their threats, that's when they decided to actually do something.

      • by Cederic ( 9623 )

        Surely after they've removed her profile she's no longer a user of their site and has no obligation to conform to their TOS?

        (leaving aside the idiocy of the TOS in the first place)

  • by Lotana ( 842533 ) on Saturday June 04, 2016 @08:09PM (#52250715)

    What if rapists post a modelling job ad in the local newspaper asking for young females. Would the newspaper be liable to be sued?

    I don't believe I ever seen any warnings in the classified sections. Surely this scenario has happened in the past. What is the precedent on those kind of cases?

  • I think you need to be really careful about putting yourself in a situation where you *can* be harmed, i.e, personal responsibility. There is no excuse for rape, robbery or any sort of violent assault however walking across a busy road while talking on a phone is pretty risky with similar consequence for injury and it's no different from anyone, female or male, taking precautions because you can be harmed through intent or negligence.

    If I was alone with a stranger I had never met I certainly would not be a

    • by Cederic ( 9623 )

      If I was alone with a stranger I had never met I certainly would not be accepting an *opened* beverage from them, even at a venue you shouldn't leave your drink unattended where you can drugged then robbed, it's the same thing, i.e Thanks, I'm not really thirsty.

      Hmm. I accept cups of coffee from complete strangers regularly.

      A one-on-one encounter with someone met through the Internet may admittedly be a reasonable justification for a little more caution. Then again, I've had male and female friends met online stay overnight at my house having never stepped into the country beforehand, so maybe I mix in different online communities to others.

  • Please NOTE (Score:5, Informative)

    by Attila Dimedici ( 1036002 ) on Saturday June 04, 2016 @10:21PM (#52251213)
    Please note that all we have here is a judge ruling that they CAN sue, not that the website is liable. All that has happened is that their lawyer made an argument that the judge agrees would be the basis for the website being liable. Now, the lawyer has to prove that the website is indeed liable. Having read the summary and the comments it appears to me that there is a basis for suing the website. Now they have to prove in a court of law that the website knew that it was being used by a rapist to lure victims and chose to take no actions. It appears from some of the comments made here that the website was not only not warning the models but actively trying to silence others who were attempting to warn potential victims (key word in that statement is "appears").
    • Please note that all we have here is a judge ruling that they CAN sue, not that the website is liable.

      This sounds strange to me. Can someone explain how this works? I thought people just sue and then a judge or jury decide if the defendant is liable. Is this an extra first step in the process?

      • Comment removed based on user account deletion
      • This is not an "extra" first step in the process. It is standard. In a normal lawsuit there are many pre-trial motions made by the lawyers on both sides. Normally, the judge rules on those motions and the trial proceeds accordingly (or not). In this case, the defendants moved to dismiss the lawsuit because they claimed a federal law prevented them from being held liable as alleged in the lawsuit. Apparently, the trial judge ruled against them and they appealed. The appeals court has now also ruled against t
  • This just in: solitary women meeting strange men alone in a dark alley are taking a risk.

    I was shocked when a female real estate agent met me on an arbitrary street corner of my choosing 100 miles from her home.

    Of course they "can" sue the site, you have a legal system that basically allows anyone to sue anyone for anything. That's the beginning of the process. Winning is something totally different.

    I'd imagine that the site would need to have actually had some degree of knowledge that the future rape was

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