Vanderbilt Law Review

First Page



A group of minors allegedly attacked a nine-year-old girl at a San Francisco beach and "artificially raped" her with a bottle. The minors attacked the girl after watching and discussing a television network movie that portrayed a similar rape. The victim sued the network, claiming that it was negligent in airing the program.' In Miami Beach, a teenage boy shot and killed his eighty-three- year-old neighbor. Following his conviction, the minor sued three television networks for damages, alleging that a decade of viewing extensive television violence had incited him to imitate the acts that he had seen. Nineteen-year-old John McCollum was listening to Ozzy Osbourne's "Speak of the Devil" album on his headphones when he shot himself in the head. The album included a song entitled "Suicide Solution." John's parents sued Osbourne and the record producer, alleging that Osbourne's music proximately caused John's death by preaching that life is filled with despair and suicide is the only way out.

Public reaction to these unsuccessful lawsuits has sparked a new movement. Some state legislatures are passing statutes that restrict minors' access to violent video cassettes, books, and other forms of expression. Vendors of expressive material have challenged Missouri and Tennessee' violence statutes. Colorado recently has passed similar restrictions on the dissemination of such material despite the uncertain constitutional status of these regulations.'