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Hosking lays down the law

By Steven | November 20, 2011

At the end of his interview about cuppagate on RNZ’s MediaWatch programme today, Mike Hosking tells us that

I think I have a pretty good appreciation of privacy law in this country.

If he means, he’s got a pretty good understanding of those laws, I think the rest of the interview demonstrates that he’s wrong.

Here’s how he describes the relevant Crimes Act provisions:

The rule is very clear and the law is very clear. Unless you have an understanding that you’re being recorded then it’s illegal to record you – that’s all part of the Crimes Act… if you go and record somebody without them knowing it, that’s against the law, and if you go and publish it without their consent, that’s against the law as well. And so the fact that there are a lot of people standing outside the window staring at you doesn’t negate your right to privacy to have what you would believe to be a private conversation…

It’s not a very accurate summary of the law. The application of the law isn’t especially clear – Andrew Geddis, Dean Knight and I have been arguing about it all week. It’s not “illegal to record” someone who doesn’t know they’re being recorded. For a start, a party to the conversation can secretly record it and not breach the Crimes Act. More relevantly, that recording must be intentional. That’s very much a live issue here, since Bradley Ambrose adamantly denies it.

In addition, it’s not illegal to publish without consent. It must be proved that the publisher knew that it was illegally intercepted. If it was unintentional, the recording was legal and anyone can disclose it without breaching the Crimes Act. If the publisher genuinely thinks the cameraman didn’t intend to intercept it, it’s hard to see how the publisher can be convicted.

Finally, much of the debate turns on whether Key and Banks ought reasonably to have expected that no-one could overhear them. The answer to that is not straightforward, whatever Hosking thinks. I still tend toward Hosking’s view – that it’s possible that the two could have reasonably expected particular parts of their conversation not to be overheard. But there are several other lawyers who disagree. At best, it’s arguable.

So when Hosking goes on to say that he’s not concerned about the media search warrants because “it’s against the law”, it doesn’t make much sense to me. Especially after he says “let’s assume the cameraman did it accidentally”. If that’s so, then there’s no crime. End of story. What’s more, anyone can publish the tape. But no, Hosking says that the editor should have told Ambrose to erase the tape “because you recorded it illegally”. Nope. Not if we’re relying on your assumption that it was accidental. Nor was it against the law if a court ultimately finds that there was a reasonable doubt about whether the parties to the conversation ought not to reasonably expect that it could be intercepted.

The search warrants are presumably being used to look for evidence of Ambrose’s intent. Some of that evidence may have been confidential statements Ambrose made to radio and television producers. Does that concern Hosking?

Hosking is very concerned about the precedent that’s created. But again, if it’s an accidental recording, it’s not a very dangerous precedent. It’s not going to happen often. And there’s still the tort of privacy, broadcasting standards and Press Council principles in the background. If it wasn’t an accidental recording and the media were to decide to publish because, after diligent inquiry, they thought it was accidental then that’s not such a terrible precedent either. That could easily have happened last Sunday.

Hosking goes on to note that the law hasn’t yet been broken. But on his argument, it had. He’d just told us that the law was clear and the recording was illegal. Perhaps he means that the media haven’t broken the law. But if Winston Peters accurately summarised what was on the tape, then there’s an argument that both he and the media (in publishing Peters’ comments) broke the law by knowingly publishing an illegally intercepted communication. (An argument. I put it no higher than that because, as we’ve seen, it would have to be proved that Winston and the media knew that the tape recording was illegal, and it’s not even clear that it was).

[Update: Hosking also said that he wouldn’t have broadcast the tape unless it showed that some law had been broken. There are several problems with that. First, that’s not a defence. To be fair, I think Hosking appreciated that; he was saying there are just times when you have to publish and be damned. Second, it’s not always going to be very clear whether a conversation is evidence of a breach of the law. What if Key was describing actions that may or may not amount to a breach of our electoral spending laws? Does Hosking get to decide? Finally, I note this distinction justifies the broadcast of an illegally recorded teacup conversation in which a minor politician says she once smoked dope, but not a conversation in which the PM says he is lying to the public about his asset sales policy.]

Hosking also praises Ambrose for going to court because “you’ll get some sort of ruling on whether it’s a public or a private conversation.” In fact, there’s no guarantee that a High Court judge will exercise his or her discretion to grant a declaration, as Dean Knight has explained.

I’m concerned that the police have taken a similar attitude. In a statement to Radio NZ, the police said:

Police considered that as the conversation had been unlawfully recorded it was necessary to advise the media at the earliest opportunity that to disclose a private conversation is potentially an offence under s 216C of the Crimes Act 1961.

This seems to suggest the police have made up their minds. I don’t think they have. The advice they gave to the media only talks of a potential offence, as does the statement I’ve quoted in an earlier paragraph. Still, it’s very sloppy language. The whole point of an investigation is to determine whether the recording was unlawful.

Topics: Journalism and criminal law, Media ethics | 379 Comments »

379 Responses to “Hosking lays down the law”

  1. deanknight Says:
    November 21st, 2011 at 7:39 am

    Spot on Steven. I had just listened to the pod cast and had a number of misgivings which your post explain so well.

    Gavin Ellis’ lay-lawyer’s view on Kathryn’s show also annoyed me.

    Given so much of this turned on tricky legal matters, why not speak to a, well, lawyer with expertise?!?

  2. thepenismightier Says:
    November 21st, 2011 at 12:11 pm

    Hosking is an idiot. Something I have come to expect, is journalists putting their 2c in where it’s i) not wanted; and ii) is factually incorrect.

    Here is my analysis of whether a crime has been committed (organised like a crims answer). As you note, it falls down on intention, but also contemporariness. I think it is moot whether a “private communication” was intercepted.

    LEGAL POSITION OF BRADLEY AMBROSE

    Crimes Act 1961

    Part 9A

    Crimes against personal privacy

    **216B Prohibition on use of interception devices**

    (1) Subject to subsections (2) to (5), every one is liable to imprisonment for a term not exceeding 2 years who *intentionally* intercepts any *private communication* by means of an *interception device*.

    To commit a crime in New Zealand, generally (and there are some minor exceptions), the prosecution must prove beyond reasonable doubt, that the defendant committed the offence (the actus reus), intentionally (the mental element / mens rea) and that they do not have a defence.

    I can identify two elements that make up the actus reus:

    i. interception of a private communication
    ii. using an interception device

    I can identify one element that makes up the mens rea
    i. intentionally

    I. So, has Ambrose intercepted a “private communication”?

    According to the Act:

    private communication—

    (a) means a communication (whether in oral or written form or otherwise) made under circumstances that may reasonably be taken to indicate that any party to the communication desires it to be confined to the parties to the communication; but

    (b) does not include such a communication occurring in circumstances in which any party ought reasonably to expect that the communication may be intercepted by some other person not having the express or implied consent of any party to do so.

    The circumstances would indicate that Key and Banks intended the communication to be private. They excluded themselves from the media. They shoed them outside. The content of their apparent discussions indicates that they were talking about politically sensitive topics.
    The only argument that could be made to counter this, would be that because they were in a public place, ie a café, they could not “reasonably to expect that the communication may be intercepted by some other person not having the express or implied consent of any party to do so”. So, if there were people walking around the café that may have been able to overhear parts of the conversation, then this may lower the standard or expectation of privacy. Probably not though, as efforts were made to ensure privacy.

    II. Was an using an interception device used?

    interception device—

    (a) means any electronic, mechanical, electromagnetic, optical, or electro-optical instrument, apparatus, equipment, or other device that is used or is capable of being used to intercept a private communication;

    I think this is pretty obvious.

    III did Ambrose act intentionally?

    This is the interesting part. Intention under law requires absolute intention. Ie, the party acted with intention, and the outcome was so obvious that the crime can be attributed to their mental state. Ambrose has said that he left the tape recorder on the table by accident. There was an apparent melee before the tea party, and in the confusion it was left there. If this is true, and there is no reason to believe it is not, Ambrose lacks intention under the Act and has thus not committed a the crime.
    The counter argument is that he did act with intention, and this can be evidenced by the fact that the recorder was in a black bag, and hidden. You could also say that because he used the tape, he intended to capture the recording seripticiously.

    If it had been hidden under the table, I think intention would speak for itself, but because this is one way or the other I don’t think he can be convicted as intention cannot be proven beyond reasonable doubt. Therefore, I think that he has not committed the crime.

    LEGAL POSITION OF SUBSEQUENT PUBLISHER

    216C Prohibition on disclosure of private communications unlawfully intercepted

    (1) where a private communication has been intercepted in contravention of section 216B, every one is liable to imprisonment for a term not exceeding 2 years who intentionally—

    (a) discloses the private communication, or the substance, meaning, or purport of the communication, or any part of it; or

    (b) discloses the existence of the private communication,— if he knows that it has come to his knowledge as a direct or indirect result of a contravention of section 216B.
    Note how this section is subsequent to section 216B – now because I don’t think that that crime has been committed (for lack of intention) it would under my interpretation of the Act / crime, not be an offence to publish it. This, however, would be contingent upon Ambrose having not committed the crime, because he lacked intent.

    Some people I have spoken to think that indirect or oblique intention could apply. This relates to situations where there was a certainty of the consequences, like throwing a baby, or shooting a person in the face. It also requires foresight. So it would have to be proven that he left the recorder there knowing full well that it was certain he would record a “private conversation”.

    It is questionable whether the conversation was private at all, and my understanding of the situation (which I have take from journos present) is that the media thought they were going to be in the cafe whilst the conversation took place, but were shoed out by security at the bequest of the owner.

    Finally, the acus reus and mens rea have to combine (contemporariness) for there to be an offence where both are elements of the crime. Therefore, because it was legal to initially place the recorder on the table, the alleged crime would be better worded as an omission. This means that there was no way for either intention or indirect intention to exist when the act was committed.

  3. Police delay searches « The Standard Says:
    November 21st, 2011 at 1:15 pm

    […] blog.  And anyone who thinks the legal issues are easy should take a read of Seven Price’s Media Law Journal: The application of the law isn’t especially clear – Andrew Geddis, Dean Knight and I have […]

  4. Glassboy Says:
    November 21st, 2011 at 2:20 pm

    Does what Ambrose did with the tape speak to intent?

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