It is not the EU. It is actually English/British law and was in place long before the EU came into existence. In England, their laws with regard to slander and libel are much more conservative in order to protect the individual from slander. In the U.S. we have this pesky little thing called the First Amendment that essentially allows anyone to say anything about someone else. In the U.S., the burden of proof to show malicious slander is so high that it is very difficult to prove. Basically, if you are public person (i.e. celebrity, sports star, elected official), it is open season for the media. Originally Posted by CpalmsonGenerally correct, at least if the victim is a public figure under U.S. law. There are advantages to each countries system. Frankly, I think that the UK system is a bit too restrictive and ours is a bit too lax as far as public figures goes. If I were alone and in charge, I might steer a middle path between the two, but that is neither here nor there. '
That being said, why it would surprise anyone that different countries have slightly different laws is beyond me.