Joyce McKinney allegedly kidnapped and raped a Morman missionary dubbed the Morman Sex Slave by the Daily Mirror. McKinney was the Diaper Wearing Astronaut of her time. Tabloid media’s entertainment value comes from invading the personal lives of notable and notorious people. Invasion of privacy laws protect people from injury from unwanted attention. Public figures like elected officials and celebrities who seek public attention seldom win lawsuits for invasion of privacy. The First Amendment protects newsworthy stories. Sensational stories may transform a private person into a limited public figure because she is related to a newsworthy event like the Manacled Morman story. When the story fades into history, does its newsworthy status evaporate? Do limited public figures like Joyce McKinney have a right to keep their notorious acts in the past? Documentary filmmaker Errol Morris’ film Tabloid investigates how tabloid stories like the Manacled Morman contort reality.
Along with the related issues of the overnight rise of “celebrities” from tabloid coverage and reality television, the subject is so prevalent, it borders on a societal obsession. It is not mere coincidence Tabloid was released, as defendants note, at a time when the News of the World phone-hacking scandal was making international headlines. It serves to underscore that issues related to tabloid journalism are of widespread public interest, and have been for years. It is indisputable the film, whatever its artistic merit, contributes “in some manner to a public discussion” of that topic.
And that McKinney remains a limited public figure whose story continues to be of public interest. Based on the numerous interviews that McKinney said she rejected over the past 35 years to protect her reputation, the story remains newsworthy.
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