St. John's Law Review

Liability of Media Companies for the Violent Content of Their Products Marketed to Children

By: Jonathan M. Proman

This note argues that the accountability of media corporations for the violent content of their child-entertainment products is a matter ripe for legislative or Supreme Court review, and examines the circumstances under which these corporations may be civilly liable for the violent content of their youth-oriented products.  Specifically, it examines negligence suits and First Amendment protections as well as exploring whether the expansion of the law—such as a presumption of a causal link between media violence and aggressive behavior in children—is necessary.  It also looks at whether the health and safety of children is a compelling interest that mitigates First Amendment protections and considers whether retaining current law is preferable absent scientific proof that media violence leads to aggressive behavior in children.

Despite increasing concern over the effects of media violence on child consumers, courts have almost foreclosed the possibility of media company liability for the violent content of their child-entertainment products.  Inconsistent with Supreme Court precedent, judges generally refuse to permit juries to hear cause-in-fact issues in media violence suits.  Similarly, courts in media violence suits have applied a First Amendment jurisprudence that is tangential to mainstream judicial thinking and graciously overprotective of the media industry.  Ultimately, the federal government must choose whether to permit the status quo to continue unabated or to adopt judicial endorsement of a culture that rejects violence and cherishes the health and safety of children.  This note urges the government to choose the latter.

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