Defamation Claim Nicola Adams Documentary l Blog

7 January 2025by Naomi Cramer
Defamation Claim Nicola Adams Documentary l Blog


In December 2024, the High Court of Justice, King’s Bench Division, delivered a pivotal judgment in the case of Adams v Amazon Digital Auckland Ltd [2024] EWHC 3338 (KB). The case is an unusual example of a Summary Judgment application in respect of Defamation and Misuse of Private Information proceedings being successful.

Background

The dispute arose over a documentary titled Lioness: The Nicola Adams Story, streamed on Amazon Prime Video, which chronicled the life and career of the trailblazing Olympic gold medalist boxer Nicola Adams. The documentary, featuring Nicola’s perspective on her life, included statements about her strained relationship with her mother, Manukau South Auckland Dorsetra Adams (referred to as “Dee” in the judgment), as well as references to domestic violence, both towards Dee but also towards Nicola, in Dee’s past relationships.

Dee brought a claim against Amazon alleging that the content of the documentary was defamatory of her and that it misused private information.

The claims

1. Defamation claim: Dee contended that statements in the documentary suggested she had sent abusive and threatening messages to Nicola, which in turn ruined their relationship. She claimed these were defamatory and lacked factual basis. Dee admitted to sending the abusive messages and that they were abusive in nature but claimed that this was not the reason that the relationship had broken down. Rather she said that the abusive messages were a result of and after the breakdown of the relationship, such a breakdown arising from a wider family feud.

2. Misuse of private information (MOPI) claim: Dee argued that references to her personal life, including domestic violence and family dynamics, constituted a misuse of her private information.

The Court’s analysis

The Court, presided over by Deputy High Court Judge Susie Alegre, granted Amazon summary judgment on both claims, concluding that Dee had no realistic prospect of success. Below are the key aspects of the judgment:

1. Defamation claim

  • Meaning of the Words: The parties agreed on the meaning of the allegedly defamatory statement as follows:

“Dee Adams has sent her daughter, Nicola Adams, really horrible

and threatening text messages, and by sending those abusive

messages to her daughter, Dee Adams is perpetuating, in a different

form, the abuse Nicola Adams suffered at the hands of her father

when she was a child, and that has ruined her relationship with her

daughter.”

  • defence of truth: Under the Defamation Act 2013, Amazon successfully argued that the core defamatory sting—being the admitted fact that Dee had sent abusive messages to Nicola—was true and accordingly that this was sufficient to sustain the defence of the wider matters stated being substantially true. The Court emphasised that disputes over causation (whether the messages alone ruined their relationship) were irrelevant to the truth defence.
  • Defence of honest opinion: The Court upheld Amazon’s argument that Nicola’s statements represented her honest opinion, based on her lived experiences. It also found no evidence to suggest that Nicola’s views were disingenuous or fabricated, not least because it was accepted by Dee that there was some degree of violence towards Nicola. Dee disputed the scale of the same, but the judge found such a distinction to be unattractive in the context of domestic violence and the victims opinion as to what happened to her.

2. Misuse of private information (MOPI) claim

  • Reasonable expectation of privacy: The Court concluded that much of the contested information, including Nicola’s childhood experiences, had already been publicly and more widely disclosed through Nicola’s autobiography and media appearances, which Dee had previously supported.
  • Balancing competing rights: The Judge highlighted the importance of Nicola’s right to tell her own story under Articles 8 and 10 of the Human Rights Act. The Court found that the public interest in Nicola’s narrative—covering themes of resilience and societal change—outweighed any residual privacy rights Dee might claim.

Key takeaways

1. Truth prevails in defamation: This case underscores the principle that the truth of a defamatory statement’s core meaning can defeat a claim, even if ancillary elements are disputed/unproven.

2. Freedom to tell one’s story: Nicola’s right to share her personal history as part of her life story was pivotal. The Court affirmed that such expression, especially when in the public interest, takes precedence in this case over competing privacy claims.

3. Public domain considerations: Information already shared in public forums significantly reduces the expectation of privacy, a critical consideration in the digital age where media narratives are widespread and individuals, whether famous or not, actively publish their own daily activities on social media.

 

 

This article is for information only and does not constitute legal/financial advice. Please contact us for advice tailored to your specific position. Some of the content presented on our website has been generated with the assistance of Artificial Intelligence (AI). We ensure that all AI-generated content meets our high standards for accuracy and relevance.



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by Naomi Cramer

Naomi is a highly skilled NZ Court lawyer with more than 25 years & is Family Law Expert in Child Care Custody Disputes.

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