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Broadcast Profanity and the Right to Be Let Alone: Can the FCC Regulate Non-Indecent Fleeting Expletives Under a Privacy Model Edward L

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Broadcast Profanity and the Right to Be Let Alone: Can the FCC Regulate Non-Indecent Fleeting Expletives Under a Privacy Model Edward L Hastings Communications and Entertainment Law Journal Volume 31 | Number 1 Article 1 1-1-2008 Broadcast Profanity and the Right to Be Let Alone: Can the FCC Regulate Non-Indecent Fleeting Expletives under a Privacy Model Edward L. Carter R. Trevor Hall James C. Phillips Follow this and additional works at: https://repository.uchastings.edu/ hastings_comm_ent_law_journal Part of the Communications Law Commons, Entertainment, Arts, and Sports Law Commons, and the Intellectual Property Law Commons Recommended Citation Edward L. Carter, R. Trevor Hall, and James C. Phillips, Broadcast Profanity and the Right to Be Let Alone: Can the FCC Regulate Non- Indecent Fleeting Expletives under a Privacy Model, 31 Hastings Comm. & Ent. L.J. 1 (2008). Available at: https://repository.uchastings.edu/hastings_comm_ent_law_journal/vol31/iss1/1 This Article is brought to you for free and open access by the Law Journals at UC Hastings Scholarship Repository. It has been accepted for inclusion in Hastings Communications and Entertainment Law Journal by an authorized editor of UC Hastings Scholarship Repository. For more information, please contact [email protected]. Broadcast Profanity and the "Right to Be Let Alone": Can the FCC Regulate Non-Indecent Fleeting Expletives Under a Privacy Model? by EDWARD L. CARTER,* R. TREVOR HALL' AND JAMES C. PHILLIPS I. Introduction .................................................................................................. 2 II. Brief Legal History of Profanity .................................................................. 7 A. Profanity Under the Common Law of Nuisance ................................... 8 B. The U.S. Supreme Court and Profanity ............................................... 12 C. Profanity's Place in the Law Today ................................................... 16 III. Free Speech Rationales and Profanity ....................................................... 22 IV. The FCC and Regulation of Profanity ....................................................... 26 A . Profanity as Indecency ........................................................................ 28 B . Profanity as Profanity ......................................................................... 34 V. Profanity and Privacy In The Home ........................................................... 36 A . C aptive A udience ................................................................................ 39 B. "Right to Be Let A lone". .................................................................... 41 V I. C onclusion .................................................................................................. 45 J.D., 2003, Brigham Young University J. Reuben Clark Law School; M.S. in Journalism, 1999, Northwestern University Medill School of Journalism; former law clerk, Hon. Ruggero J. Aldisert, U.S. Court of Appeals for the Third Circuit; contact: ed [email protected]. The authors acknowledge the research assistance of Brigham Young University undergraduate students Tim Ray, Josh Cook, Mitch Olsen, Jeff Erekson and Christopher Lindsay. ' Ph.D., 2001, Communication Studies, Northwestern University School of Speech; M.A., 1999, Communication Studies, Northwestern University School of Speech; contact: [email protected]. 2 HASTINGS CoMMIENT L.J. [31:1 I. Introduction Congress has empowered the Federal Communications Commission to regulate "obscene, indecent, or profane language" in broadcasting.' Obscenity, defined 35 years ago by the U.S. Supreme Court as patently offensive depictions or descriptions of sexual conduct that lack aesthetic or scientific content and appeal to a morbid or prurient interest, enjoys no protection under the Constitution's First Amendment and may not be broadcast over the airwaves at any time.2 Indecency, meanwhile, has been defined by the FCC as "patently offensive references to excretory and sexual organs and activities";3 the First Amendment prohibits the government from completely banning indecent material, but restrictions on the times during which indecency may appear via broadcast airwaves have been approved by the Supreme Court.4 The most undefined-and, until recently, the most ignored-portion of 18 U.S.C. § 1464 concerns "profane language." Given the Supreme Court's 2008 Term consideration of an appeal in FCC v. Fox Television Stations, Inc.,5 however, that will apparently change. The Court scheduled oral arguments for November 4, 2008. The term "profane language" admits no easy definition, let alone general agreement regarding its place in American society and the extent to which the government should attempt to regulate it.6 The 1. 18 U.S.C. § 1464 (2008). 2. Miller v. California, 413 U.S. 15, 23 (1973) ("This much has been categorically settled by the Court, that obscene material is unprotected by the First Amendment."). 3. FCC v. Pacifica Found., 438 U.S. 726, 743 (1978). 4. Id. 5. Fox Television Stations, Inc. v. FCC, 489 F.3d 444 (2d Cir. 2007), cert. granted, 128 S.Ct. 1647 (Mar. 17, 2008). 6. In the days immediately following the Supreme Court's grant of certiorari in the Fox case, for example, a handful of newspaper editorial writers railed against allowing the government to ask broadcasters to stop certain profanities. For example, the Concord Monitor editorialized against the FCC's position in the Supreme Court case, arguing that "f-" and "s-," when used on live television in 2002 and 2003, had nothing to do with sex or excretion. See Unsigned Editorial, A Slip Of the Tongue Shouldn't Mean a Fine, CONCORD MONITOR, April 9, 2008. See also Unsigned Editorial, Broadcast TV and 'Fleeting Obscenities,' ROCKY MOUNTAIN NEWS, March 23, 2008, at 5 (urging the Supreme Court to affirm the Second Circuit's opinion); Unsigned Editorial, Dirty Word Games, L.A. TIMES, March 22, 2008, at 22 (same). On the other hand, in an editorial published in USA Today, FCC Chairman Kevin J.Martin cited statistics indicating that three-fourths of adults in the United States support the FCC's efforts to enforce strict standards regarding profanity and indecency on television. See Kevin J. Martin, Defenses Can And Do Fail, USA TODAY, March 31, 2008, at 11A. Martin also cited a Parents 20081 BROADCAST PROFANITY current Supreme Court appeal pits a newly aggressive content regulator in the FCC versus a newly aggressive broadcast industry led, in this case, by Rupert Murdoch and his News Corporation' but joined also by erstwhile competitors NBC, CBS and ABC.8 Rhetoric abounds from both sides of the debate. Timothy F. Winter, president of the Parents Television Council, wrote in a newspaper op-ed piece that the lower court decision invalidating the FCC's new approach "had, in essence, stolen the airwaves from the public and handed ownership over to the broadcast industry." 9 Meanwhile, broadcast executives claim a loss in the case for them would mean the death of live television."° In light of the FCC's decision now to act on Congress' command to regulate its use in broadcasting," profanity must be considered from social, historical and legal perspectives apart from obscenity and indecency. One scholar noted that the Latin roots of the word "profane" connote "to desecrate or violate a temple"; this blasphemy-related Television Council study finding that profanity had increased on "family hour" TV 95 percent between 1998 and 2002. Id. 7. In what the Washington Post called an "unusually aggressive step" that signaled its all-out war on decency regulation, Fox in March 2008 refused to pay $91,000 in fines stemming from a 2003 broadcast of a show called "Married By America" that featured digitally obscured nudity--even though the FCC had agreed to reduce the fines from a total of $1.2 million. See Frank Ahrens, Fox Refuses to Pay 2004 Indecency Fine, WASHINGTON POST, March 25, 2008. 8. An unrelated but similar challenge to the FCC's suddenly more strict approach to regulating indecency on television resulted in the U.S. Court of Appeals for the Third Circuit vacating a $550,000 forfeiture order against CBS for the brief, unscripted broadcast of Janet Jackson's exposed breast during the Super Bowl halftime show in 2004. See CBS Corp. v. FCC, 535 F.3d 167 (3d Cir. 2008). 9. Timothy F. Winter, Profanity On Airwaves Not a "Right," FLORIDA SUN- SENTINEL, April 13, 2008, at 5F. Winter stated that virtually no parents want their children exposed to even a single profanity "on the street, let alone ... [in] their living rooms during the early evening hours on network television." Id. He said broadcasters could institute a five-second delay but choose not to, and he warned the Supreme Court that a decision to affirm the holding of the U.S. Court of Appeals for the Second Circuit "would defy overwhelming public sentiment." Id. Even Winter, though, seemed to realize that the current Supreme Court case likely won't resolve the issue; he called on Congress to explicitly state that fleeting expletives are prohibited on daytime and evening broadcast television. Id. 10. Frank Ahrens, TV Decency Showdown Heads to Supreme Court, ST. PAUL PIONEER-PRESS, April 13, 2008, at A8. 11. See 18 U.S.C. § 1464; FCC, In the Matter of Various Complaints Against Broadcast Licensees Regarding Their Airing of the "Golden Globe Awards" Program, 19 F.C.C.R. 4975, 4978-80 (March 18, 2004). 4 HASTINGS COMM/ENT L.J. [31:1 meaning has evolved now to encompass "more secular objects." 2 Thus, profanity came to include within its ambit the demeaning of sex; the word "obscenity," too, had its beginnings in sacrilege before moving
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