Within the EU, this is relatively straightforward. The Brussels Regime provides a framework for one member state to enforce the judgement of the Courts in another member state.
Within the US, there is also (in most cases) a mechanism for the enforcement of a foreign (i.e. UK) monetary judgements, but this isn't automatic by any means and is dependent on state law.
It should be noted that, in both cases, such judgements won't be honoured if the appeal process is still ongoing.
Within the EU, this is relatively straightforward. The Brussels Regime provides a framework for one member state to enforce the judgement of the Courts in another member state.
Within the US, there is also (in most cases) a mechanism for the enforcement of a foreign (i.e. UK) monetary judgements, but this isn't automatic by any means and is dependent on state law.
It should be noted that, in both cases, such judgements won't be honoured if the appeal process is still ongoing.
I have no idea what the submitter is referring to when he claims that the UK lacks a right to free speech. The article itself makes no such claim, although it does go on to raise other issues that are less easy to argue with.
As a result of the Human Rights Act 1998, any body acting in a public manner, not just in a vertical (governmental) relationship as in the US Bill of Rights, is required to act in accordance with ECHR articles. Article 10 guarantees a right to freedom of expression, limited only in accordance with law, and only where such laws are found to be necessary for a functioning democratic society. As another commenter points out above, neither this, nor the US's first amendment, are apt to shield defamers from litigation.
On another note, I don't appreciate the UK being referred to as a whole in this matter, we in Scotland have a distinct legal system and this is more relevant in regard to defamation than in almost any other area.
If you take issue with our defamation law, that's something you need to raise with the EU, where most of our modern development in this regard, especially electronic correspondence, comes from. However, it's irresponsible and misleading to imply that we lack basic respect for a right to free speech.
Slashdot Mirror
(repeat from below)
Within the EU, this is relatively straightforward. The Brussels Regime provides a framework for one member state to enforce the judgement of the Courts in another member state.
Within the US, there is also (in most cases) a mechanism for the enforcement of a foreign (i.e. UK) monetary judgements, but this isn't automatic by any means and is dependent on state law.
It should be noted that, in both cases, such judgements won't be honoured if the appeal process is still ongoing.
The Brussels Convention - http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:41968A0927(01):EN:HTML
Uniform Foreign Money Judgments Recognition Act 1962 - http://www.law.upenn.edu/bll/archives/ulc/fnact99/1920_69/ufmjra62.pdf
Within the EU, this is relatively straightforward. The Brussels Regime provides a framework for one member state to enforce the judgement of the Courts in another member state.
Within the US, there is also (in most cases) a mechanism for the enforcement of a foreign (i.e. UK) monetary judgements, but this isn't automatic by any means and is dependent on state law.
It should be noted that, in both cases, such judgements won't be honoured if the appeal process is still ongoing.
The Brussels Convention - http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:41968A0927(01):EN:HTML
Uniform Foreign Money Judgments Recognition Act 1962 - http://www.law.upenn.edu/bll/archives/ulc/fnact99/1920_69/ufmjra62.pdf
I have no idea what the submitter is referring to when he claims that the UK lacks a right to free speech. The article itself makes no such claim, although it does go on to raise other issues that are less easy to argue with.
As a result of the Human Rights Act 1998, any body acting in a public manner, not just in a vertical (governmental) relationship as in the US Bill of Rights, is required to act in accordance with ECHR articles. Article 10 guarantees a right to freedom of expression, limited only in accordance with law, and only where such laws are found to be necessary for a functioning democratic society. As another commenter points out above, neither this, nor the US's first amendment, are apt to shield defamers from litigation.
On another note, I don't appreciate the UK being referred to as a whole in this matter, we in Scotland have a distinct legal system and this is more relevant in regard to defamation than in almost any other area.
If you take issue with our defamation law, that's something you need to raise with the EU, where most of our modern development in this regard, especially electronic correspondence, comes from. However, it's irresponsible and misleading to imply that we lack basic respect for a right to free speech.
I_A_AL, he clearly isn't.