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Paul Grange and Hillsborough Disaster

Closed Mixed Outcome

Key Details

  • Mode of Expression
    Non-verbal Expression
  • Date of Decision
    July 8, 2016
  • Outcome
    Decision Outcome (Disposition/Ruling), Monetary Damages / Fines
  • Case Number
    N/A
  • Region & Country
    United Kingdom, Europe and Central Asia
  • Judicial Body
    First Instance Court
  • Type of Law
    Criminal Law
  • Themes
    Hate Speech

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Case Analysis

Case Summary and Outcome

A U.K. Court fined the Defendant, Paul Grange, under the Public Order Act of 1986 after he wore a shirt referring to the 1989 Hillsborough Disaster as God’s way of dealing with a pest problem. As Grange pleaded guilty to the offense, this case does not set any precedent value for other freedom of expression cases. However, the conviction itself raises some freedom of expression concerns as the shirt, although in extremely bad taste, did not directly threaten any person. The sentencing is yet another illustration of the difficulty in drawing the line between free speech and hate speech.

“Global FoE could not identify official legal and government records on the case and case information was derived from secondary sources. Global FoE notes that media outlets may not provide complete material and additional information regarding legal matters will be updated as an official source becomes available.”


Facts

Paul Grange ordered a Tshirt from a printing company with a message referring to the 1989 Hillsborough disaster as God’s way of dealing with a pest problem. He was thrown out of the pub he wore it to and a picture taken of the shirt by a passerby went viral on social media. Grange was arrested under the Public Order Act of 1989, which punishes someone who “displays any writing, sign or other visible representation which is threatening, abusive or insulting, within the hearing or sight of a person likely to be caused harassment, alarm or distress thereby.” 

Grange pleaded guilty to the offense and expressed remorse for what he had done, noting that the shirt had merely been banter between himself and his friends and he had not intention of causing harm. Family members of the victims said seeing the images on the shirt had caused them harm.

Grange was fined £6oo for the offense and ordered to pay £135 in court costs and a £60 victim surcharge.

 


Decision Overview

The chair of the magistrates bench, Sue Dowty, told Grange: “This offence carries a maximum penalty of a fine. In coming to the fine we have taken into account your remorse, balanced by the distress caused to people.”

The magistrates also ordered the forfeiture and destruction of the T-shirt and a second shirt bearing similar offensive comments.


Decision Direction

Quick Info

Decision Direction indicates whether the decision expands or contracts expression based on an analysis of the case.

Mixed Outcome

As Grange pleaded guilty to the offense, this case does not set any precedent value for other freedom of expression cases. However, the conviction itself raises some freedom of expression concerns as the shirt, although in extremely bad taste, did not directly threaten any person. The sentencing is yet another illustration of the difficulty in drawing the line between free speech and hate speech.

Global Perspective

Quick Info

Global Perspective demonstrates how the court’s decision was influenced by standards from one or many regions.

Table of Authorities

National standards, law or jurisprudence

  • U.K., Public Order Act of 1986

Case Significance

Quick Info

Case significance refers to how influential the case is and how its significance changes over time.

This case did not set a binding or persuasive precedent either within or outside its jurisdiction. The significance of this case is undetermined at this point in time.

Official Case Documents

Reports, Analysis, and News Articles:


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