Libel in the US: you wrote something that is demonstrably false. You can say anything you want as long as it's clear that it's your opinion and not being presented as fact.
That wouldn't fly in a US libel trial. The plaintiff would have to prove that the person who wrote it intended the reader to understand that she was literally a member of the Nazi party and that it wasn't simply hyperbole.
You needn't preface a comment with "in my opinion", it's sufficient if a reasonable person would interpret your statement as an opinion. Given that whatever version of the Nazi party still exists is an extremely fringe group and that it's a common internet insult to call someone a Nazi, you would have to pretty much explicitly state that you are in fact saying someone is a member of the Nazi party for this to get any traction in a US court.
The plaintiff would have to prove that the person who wrote it intended the reader to understand that she was literally a member of the Nazi party and that it wasn't simply hyperbole.
If Rowling were a member of a nationalist party, I suspect that one might be able to get away with calling her a Nazi.
Note the SNP aren't going around litigating against people calling them Nazis, because Nationalism and Socialism are literally their party manifesto, and the last thing they'd want in a newspaper is a court transcript of two lawyers arguing about how accurate it is to call them Nazis.
Libel in the US: you wrote something that is demonstrably false. You can say anything you want as long as it's clear that it's your opinion and not being presented as fact.
Libel in the UK: you wrote something mean.
'JK Rowling is a Nazi' IS demonstrably false, though.
That wouldn't fly in a US libel trial. The plaintiff would have to prove that the person who wrote it intended the reader to understand that she was literally a member of the Nazi party and that it wasn't simply hyperbole.
You needn't preface a comment with "in my opinion", it's sufficient if a reasonable person would interpret your statement as an opinion. Given that whatever version of the Nazi party still exists is an extremely fringe group and that it's a common internet insult to call someone a Nazi, you would have to pretty much explicitly state that you are in fact saying someone is a member of the Nazi party for this to get any traction in a US court.
So the standard for justice is normalization. How very “democratic”. Totally in keeping with our constitutional republic.
If Rowling were a member of a nationalist party, I suspect that one might be able to get away with calling her a Nazi.
Note the SNP aren't going around litigating against people calling them Nazis, because Nationalism and Socialism are literally their party manifesto, and the last thing they'd want in a newspaper is a court transcript of two lawyers arguing about how accurate it is to call them Nazis.