CELEBRITY JUSTICE AND GOSSIP BLOGS: DEMOGRAPHIC CHARACTERISTICS OF VICTIMIZED AND ALLEGEDLY CRIMINAL CELEBRITIES FEATURED ON TOP GOSSIP BLOGS

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1 244 CELEBRITY JUSTICE AND GOSSIP BLOGS: DEMOGRAPHIC CHARACTERISTICS OF VICTIMIZED AND ALLEGEDLY CRIMINAL CELEBRITIES FEATURED ON TOP GOSSIP BLOGS Carmen M. I. INTRODUCTION In the song Lifestyles of the Rich and Famous, the band Good Charlotte articulates the perceived problem with celebrities, society, and the criminal justice system. 1 Good Charlotte sings: Always see it on T.V. or read it in the magazines, celebrities want sympathy. All they do is piss and moan inside the Rolling Stone, talking about how hard life can be. I'd like to see them spend a week living life out on the street. I don't think they would survive, if they could spend a day or two walking in someone else's shoes. I think they'd stumble and they'd fall Benji Madden & Joel Madden, Lifestyles of the Rich and Famous (2001).

2 245 Lifestyles of the rich and the famous.... Well, did you know when you were famous you could kill your wife and there's no such thing as 25 to life? As long as you've got the cash, to pay for Cochran; and did you know if you were caught and you were smoking crack... you could always just run for mayor of D.C. This article neither defends, nor denies Good Charlotte s perspective. Instead, this article asks: Who are the subjects of these T.V./magazine stories? Once this question is answered, this article asks: What significance the answer could have for celebrity justice; the effect of the press and public opinion on the criminal justice system; and the criminal justice system on the press and public opinion; the effect of society, media, and the criminal justice system on celebrity; and the effect of celebrity criminality or celebrity justice on crime. This article relies on law review articles and original research on celebrity blogs between the years 2008 and Section II reviews the concepts of celebrity justice and jury bias towards

3 246 certain demographic characteristics that could relate to the perceived phenomenon of celebrity justice and media coverage of criminal cases involving celebrities. Section III discusses the methods used to sample data from four top celebrity gossip blogs. 2 This section also presents findings on the gender, race, and occupation of the most widely covered celebrities involved in criminal cases, sampled in the collected data. Section IV questions the purpose and effects of these celebrity demographics, and proposes new research questions. These new suggested angles should be investigated in order to formulate the fullest picture of the interplay between media, criminal justice, society, and celebrities. The article concludes by summarizing the practical and potential importance of understanding which demographic of celebrities celebrity bloggers commonly identify as victims and perpetrators of crimes. 2 Jared Chamberlain et al., Celebrities in the Courtroom: Legal Responses, Psychological Theory and Empirical Research, 3 VAND. J. ENT. & TECH. L. 551, (2006).

4 247 II. A FACTUAL AND ANECDOTAL COMPARISON BETWEEN CELEBRITY CRIME AND JUSTICE AND NON- CELEBRITY CRIME AND JUSTICE A. Juicy Gossip: Celebrity Justice and the Murder Trial of OJ Simpson The blogosphere serves to perpetuate information as well as communicate or influence opinion. 3 Previously, people relied on network or newspaper journalists to communicate information. 4 Today, people want bloggers to reveal and lead the masses through information gathered from often anonymous reliable sources or the bloggers 3 See Lenna Garibian, "Digital Influence: Blogs Beat Social Networks for Driving Purchases," Marketing Profs (Mar. 18, 2013) (last visited on May 1, "Blogs Influence Consumer Purchases More than Social Networks," MarketingCharts, Oct. 31, 2008 (last visited May 1, Sara Sun Beale, The News Media's Influence on Criminal Justice Policy: How Market- Driven News Promotes Punitiveness, 48 WILLIAM & MARY L. REV. 397 (2006). 4 Andrew Beaujon, "N.J. Judge Revives Blogger vs. Journalist Debate," Poynter, Feb. 5, 2013 (last visited May 1, 2013). for the proposition that bloggers may not be journalists).

5 248 personal opinions about current events. 5 Celebrity bloggers opinions about celebrities can influence popular culture and celebrities popularity. 6 But can it influence public perception about a fundamental tenet of our society: the criminal justice system? 7 Celebrity justice describes a phenomenon in which the public perceives that celebrities are engaged in an atypical form of justice due to their celebrity. 8 Celebrity status has been described by members of the public, legal commentators, and the media as influencing the system and individual members of the system, as well as influencing the public at large. 9 The media s coverage of celebrity 5 Id. 6 People in Español listed celebrity gossip blogger, Perez Hilton, as one of the fifteen most influential Latinos in the United States. See About, PEREZHILTON.COM (last visited May 1, Catherine Stehlin, Casenote: Is Open Voir Dire "A Good Thing"? ABC, Inc. V. Martha Stewartn1: The Second Circuit's Interpretation of First Amendment Rights During Jury Selection in High-Profile Celebrity Trials, 12 VILL. SPORTS & ENT. L.J. 297, 326 (2005). 8 Jared Chamberlain et al., Celebrities in the Courtroom: Legal Responses, Psychological Theory and Empirical Research, 3 VAND. J. ENT. & TECH. L. 551, (2006). 9 Jared Chamberlain et al., Celebrities in the Courtroom: Legal Responses, Psychological Theory and Empirical Research, 3 VAND. J. ENT. & TECH. L. 551, (2006).

6 249 cases may influence or exacerbate this dynamic. 10 Inquiries into celebrity justice are now common so common that Celebrity Justice is a category of newsfeed on FindLaw.com. 11 Numerous sensationalized celebrity criminal verdicts have been decided in parity with the criminal justice system s traditional biases, including biases against young, male minorities. 12 One of the most sensationalized cases, O.J. Simpson s murder trial, was one of the first instances in which celebrity justice diverged from traditional racial biases in the criminal justice system. 13 In addition to the presence of cameras in the courtroom, which transmitted every detail of the 10 "Alan Dershowitz: Celebrity Justice Is an Oxymoron': Harvard Law Professor Says Celebs Fare Better in Court for Serious Crimes, ABC News, Sep. 17, 2012 (last visited Feb. 21, FindLaw.com, Celebrity Justice (last visited Feb. 15, Jared Chamberlain et al., Celebrities in the Courtroom: Legal Responses, Psychological Theory and Empirical Research, 3 VAND. J. ENT. & TECH. L. 551, (2006). 13 "Resources from the former CWLA Federal Resource Center for Children of Prisoners: An Overview of Statistics," Family & Corrections Network, National Resource Center on Children and Families of the Incarcerated (last visited Feb. 17, 2013

7 250 case and caused audiences to polarize behind the prosecution or the defense, the demographic divergence may have played a part in why people decried celebrity justice. 14 An African American man had allegedly murdered a European American woman. 15 Both were young, attractive, and wealthy, but only the defendant was famous. 16 The verdict challenged traditional prejudices and expectations. 17 Many people attributed this decision to Simpson s expensive legal counsel and celebrity status. 18 Because the verdict happened to defy traditional biases, some observers claimed that Simpson s jury intentionally attempted to establish equality by 14 Catherine Stehlin, Is Open Voir Dire "A Good Thing"? ABC, Inc. v. Martha Stewartn: The Second Circuit's Interpretation of First Amendment Rights During Jury Selection in High-Profile Celebrity Trials. 15 Jared Chamberlain et al., Celebrities in the Courtroom: Legal Responses, Psychological Theory and Empirical Research, 3 VAND. J. ENT. & TECH. L. 551, 560 (2006). 16 Id. 17 Id. 18 Jared Chamberlain et al., Celebrities in the Courtroom: Legal Responses, Psychological Theory and Empirical Research, 3 VAND. J. ENT. & TECH. L. 551 (2006).

8 251 countering past biases inflicted by police forces and other criminal justice members. 19 Interestingly, Simpson was convicted of kidnapping and robbery in Nevada in Unlike his murder trial, that trial was not highly sensationalized, the jurors were not sequestered, and Simpson did not hire a dream team of celebrity lawyers. 21 The nation was not divided: the accused was no longer as attractive, young, sporty, famous, or wealthy and the victim was not a young, wealthy, European-American female. 22 Of the jury that convicted him in 2008, Simpson recently said, I 19 Id. In addition to the parties races, the criminal justice members races and genders may or may not also play a factor. See Besiki Kutateladze et al., Do Race and Ethnicity Matter in Prosecution? A Review of Empirical Studies, Vera Institute of Justice (2012) (last visited on May 1, 2013), See also generally Herbert C. Lenese, A Perspective on Black Prosecutors' Loyalty within the American Criminal Justice System, 49 HOWARD L. J. 495 (2006); Todd Lochner & Dorie E. Apollonio, The Effect of a Prosecutor's Gender on Federal Prosecutorial Decision Making and Area of Practice, W. Pol. Sci. Ass n (2012) (last visited on May 1, Philip Recchia, "O.J. Simpson Talks About Prison Life, Plans after He's Released," May 19, 2013 (last visited May 20, E9YSL0m68rJRnV5tnDVN/2). 21 Id. 22 Id.

9 252 feel like I m back in the 50s a black man in a white justice system I looked into their eyes and I knew they would convict me. 23 B. Biases: We, the Jury, Find the Defendant to be Attractive and Wealthy In their article, Celebrities in the Courtroom: Legal Responses, Psychological Theory and Empirical Research, Jared Chamberlain, Monica K. Miller, and Alayna Jehl report on a number of social science studies about the relationship between jury decision-making and demographic factors, such as attractiveness, racial heritage, gender, and socio-economic status. 24 Chamberlain, Miller, and Jehl reported that unattractive defendants were given more severe sentences than attractive defendants. 25 This should lead scholars to question whether a jury of 23 Id. 24 Jacob Chamberlain et al., Celebrities in the Courtroom: Legal Responses, Psychological Theory and Empirical Research, 3 VAND. J. ENT. & TECH. L. 551, 552 (2006). 25 Chamberlain et al., 3 VAND. J. ENT. & TECH. L. 551, 552.

10 253 one s peers would find particular traits to be attractive. Celebrities may receive better justice or better press because they present better. 26 Politicians, actors, musicians, personalities, and athletes may better control their voices, involuntary reactions, and posture, and they may be more captivating entertainers than the average person. 27 They may also be more photogenic. 28 Essentially, celebrities may be like illusionists who use persona, character, words, mind, face, clothes, and body rather than flowers, cards, top hats, wands, capes, smoke, and mirrors. The public, including juries and bloggers, may confuse attraction to the celebrity with trust for the celebrity. 29 Alan M. Dershowitz 26 Chamberlain et al., 3 VAND. J. ENT. & TECH. L. 551, Jesse Bering, "18 Attributes of Highly Effective Liars," Scientific American, Jul. 7, 2011 (last visited May 15, attributes-of-highly-effective-liars/). 28 Chamberlain et al., 3 VAND. J. ENT. & TECH. L. 551, The principal reason is that an American jury innately influenced by our nation's celebrity-obsessed culture is far more likely to trust a well-known musician than they would an unknown performer or songwriter. Eric M. Leventhal, Note, Would You Want William Hung as Your Trier of Fact? The Case for a Specialized Musicology Tribunal, 90 TEX. L. REV. 1557, 1582 (2012). Interestingly, Mr. Leventhal s article references the possibility that William Hung could

11 254 said that the virtue of putting a celebrity witness on the stand is that her testimony would likely overshadow the other evidence. The jury would base its verdict largely on whether they believed or disbelieved her (or liked or disliked her)." 30 To jurors, celebrities may appear to be more trustworthy witnesses or forgivable defendants because they may be more physically or economically appealing. 31 Another study suggested that jurors were more likely to give males more severe fines for aggressive behavior, while females were more severely punished for non-criminal behavior. 32 Gender and race differences may play into or away from these inclinations, depending on who sits on the jury and how they perceive these be the trier of fact. See id. The author does not note that William Hung played himself on Episode 10 of Season 3 of Arrested Development. In that episode, the Bluth family is conducting a mock trial. The mock trial is being televised as a courtroom drama. The court is presided over by Judge Reinhold. Hung and his band, William Hung & His Hung Jury, sing break teases from the jury box. See Youtube, Mock Trial with Judge Reinhold, Nov. 6, 2011 (last visited Feb. 20, 2013, 30 Leventhal, 90 TEX. L. REV. 1557, 1582, n.172 (2012). 31 Chamberlain et al., 3 VAND. J. ENT. & TECH. L. 551, Chamberlain et al., 3 VAND. J. ENT. & TECH. L. 551, 552.

12 255 factors in addition to how they feel about a particular celebrity s occupation. 33 In general, celebrity athletes have been stereotyped by the public as violent even though studies demonstrated that athletes are better at dealing with anger than non-athletes. 34 This stereotype may have influenced public perception during Simpson s murder trial. 35 Could it have influenced police, investigators, jurors, prosecutors, experts, or the judge? 36 Celebrity athletes are also stereotyped as drug abusing and lacking intelligence. 37 This stereotype suggests that athletes might be at a significant disadvantage in the 33 See generally Christopher T. Robertson, David V. Yokum, and Matt J. Palmer, The Inability of Jurors to Self-Diagnose Bias, Apr. 24, 2013, 7th Annual Conference on Empirical Legal Studies Paper, Arizona Legal Studies Discussion Paper No (last visited May 15, Samuel McNerney, "The Bias within the Bias," Scientific American, May 15, 2013 (last visited May 16, Chamberlain et al., 3 VAND. J. ENT. & TECH. L. 551, 556; See Brad J. Bushm et al., Do People Aggress to Improve Their Mood? Catharsis Beliefs, Affect Regulation Opportunity, and Aggressive Responding, 81 J. PERSONALITY & SOC. PSYCHOL. 17 (2001). 35 Chamberlain et al., 3 VAND. J. ENT. & TECH. L Carmen M., A Feminist Inquiry into Intimate Partner Violence Law, Policy, Policing, and Possible Prejudices in Alaska, 5 J. L & CONFLICT RES. 24 (2013). 37 Chamberlain et al., 3 VAND. J. ENT. & TECH. L. 551, 556.

13 256 legal system if jurors subscribe to these negative beliefs. 38 On the other hand, juries may believe that unintelligent athletes lack the ability to plan crimes carefully. 39 A study of arrest and conviction records of famous athletes from across the country [demonstrate] that athletes were more likely to be arrested for sexual assault than nonathletes, but that athletes were more likely to be acquitted than nonathletes. 40 The author did not report demographic variations between factors such as racial heritage, age, sex, status, and wealth, though these factors may have correlated to the findings about celebrity athletes. 41 Chamberlain, Miller, and Jehl reported jurors indication that defendants in low socio-economic brackets received significantly higher sentences than similarly 38 Chamberlain et al., 3 VAND. J. ENT. & TECH. L. 551, Id. 40 Id. 41 Id.

14 257 situated defendants in high socioeconomic brackets. 42 Juries evaluations of the defendants culpability, personality, and character may be affected by factors like a celebrity s economic disadvantage or unemployment, which could possibly include loss of endorsements or contracts. 43 Could these biases, including the loss of endorsements, also affect the prevalence of the celebrity s appearance on gossip blogs or coverage in the mainstream media? Applying the studies reported by Chamberlain, Miller, and Jehl to Simpson s murder trial, several traditional and predictable biases possibly overlapped in his favor and to his detriment. 44 Thus, the trial and verdict polarized the 42 Id. at Id. at Stehlin, 12 VILL. SPORTS & ENT. L.J. 297, 305 (2005). In addition to the hardships associated with finding impartial jurors, celebrity trials may frustrate public policy. In particular, if celebrity trial judges need to go out of their way to use various judicial techniques to protect the rights of celebrities, then justice is not shaped by laws, but rather, manipulated according to whom the laws are being applied. See Alan Dershowitz: 'Celebrity justice is an oxymoron': Harvard law professor says celebs fare better in court for serious crimes," ABC NEWS, Sep. 17, 2012, last visited Feb. 21, 2013, See also generally Laurie L. Levenson,

15 258 nation. 45 Irrespective of one s perception of his guilt or innocence, many people agreed that Simpson s quality of justice differed markedly because of the extent of his jury s sequestration, the unfettered presence of press in the courtroom, Simpson s celebrity, and his expensive and renowned legal team. 46 How could laypeople arrive at sophisticated conclusions about the qualifications of his legal team, due process, criminal procedure, and other factors involved? 47 The media provided the public with the foundational facts, and built the requisite framework to contextualize those facts. 48 C. The Power of Celebrity Blogs and Bloggers 1. Could Pop Blogs Choose the View of Who Popped the Clog? Symposium on Trials of the Century: Cases of the Century, 33 LOY. L.A. L. REV. 585 (2000). 45 Id. 46 Stehlin, 12 VILL. SPORTS & ENT. L.J. 297 (2005). 47 Id. 48 Id.

16 259 Today, people look to bloggers to digest the facts for them and spin these facts. 49 People may read blogs because they enjoy the factual content and the bloggers voices, which can incorporate biases. 50 Bloggers may not work under the same ethical considerations as reporters and may be under no obligation to portray their personal opinions truthfully. 51 As long as the bloggers avoid defamation and other unprotected speech acts, then they can lead their audiences to accept incorrect information or biased opinions that do not reflect the facts accurately, their true understanding of cases, or their first-hand or genuine opinions about the celebrities. 52 Gossip bloggers are under no 49 See, Lenna Garibian, "Digital Influence: Blogs Beat Social Networks for Driving Purchases," Marketing Profs, Mar. 18, 2013 (last visited on May 1, "Blogs Influence Consumer Purchases More than Social Networks," MarketingCharts, Oct. 31, 2008 (last visited May 1, Sara Sun Beale, The News Media's Influence on Criminal Justice Policy: How Market- Driven News Promotes Punitiveness, 48 WILLIAM & MARY L. REV. 397 (2006). 50 Id. 51 Id. 52 Id.

17 260 obligation to demonstrate to the public that there is not a separate court system for celebrities, and ensure that celebrity defendants are... afforded the opportunity for a fair trial. 53 Bloggers influence can be wide-reaching, and may extend into the courtroom. 54 The information provided by the media creates a larger population of potential jurors with pre-set notions about the case, and about the justice that should be afforded to the defendant s demographic. 55 If celebrity blogs are believed to represent influential bloggers opinions about celebrity justice, then could blogs also influence the blog audience s thoughts about the role of justice in their own demographic to the same degree that the mainstream media did in Simpson s trial? 56 Could 53 Stehlin, 12 VILL. SPORTS & ENT. L.J. 297, 326 (2005). 54 Associated Press, "Judge Dismisses Jury after Panelist Goes Online," BOWLING GREEN DAILY NEWS, Apr. 11, 2013 (last visited Apr. 11, 2013), dismisses-jury-after-panelist-goes-online/article_fadd2221-b229-55d5-a3fa-e729502fd08d.html. 55 Stehlin, 12 VILL. SPORTS & ENT. L.J. 297, 303 (2005). 56 Jared Chamberlain et al., Celebrities in the Courtroom: Legal Responses, Psychological Theory and Empirical Research, 3 VAND. J. ENT. & TECH. L. 551 (2006). Freddie Allen, Blacks Are Disproportionately Represented in Drug Arrests and Prison

18 261 the blogosphere influence mainstream media s perceptions, which may have an even greater effect on the public and potentially the trier of fact? Sword of Destiny 58 Some people believe that celebrity justice can be a double-edged sword because celebrities occasionally are made into public examples. 59 Because celebrities receive so much media coverage, members of the justice system may want to castigate celebrities harshly to send a message to the public. 60 Robert Shapiro, who represented a Sentences, Louisiana Weekly, Jan. 14, 2013, last visited Feb. 21, People in Español listed celebrity gossip blogger, Perez Hilton, as one of the fifteen most influential Latinos in the United States. See PerezHilton.com, About (last visited May 1, See Garibian, "Digital Influence: Blogs Beat Social Networks for Driving Purchases"; "Blogs Influence Consumer Purchases More than Social Networks"; Beale, "The News Media's Influence on Criminal Justice Policy: How Market-Driven News Promotes Punitiveness. "Judge Dismisses Jury after Panelist Goes Online," BOWLING GREEN DAILY NEWS. 58 Arrested Development Season 2, Episode Stehlin, Casenote, Is Open Voir Dire "A Good Thing"? ABC, Inc. v. Martha Stewart: The Second Circuit's Interpretation of First Amendment Rights During Jury Selection in High-Profile Celebrity Trials. 60 See Rich Juzwiak, Joe Francis Juror Responds, Confirms He Is Not Retarded, GAWKER, May 22, 2013 (last visited May 23, 2013

19 262 number of celebrities, says that before he represented Simpson during his murder trial, he often spoke to the media. 61 Following the trial, which Shapiro considers the original reality show, he no longer attempts to curb bad press for his clients by speaking to the media because clients can be crucified. 62 Joe Franics, defendant and creator of Girls Gone Wild, was found guilty of false imprisonment committed against three female dates. Id. After being told that he ought to be shot and having been called retarded by Franics, a jurymember said, A lot of the older people on [the jury] had no idea who [Franics] was. Some of us did, though. During jury selection, Francis lawyer Steve Levine asked a pool I was in at one point, How many people have heard of Joe Francis? A whole bunch of people, including me, raised our hands. He said, OK, that s fine. I m not going to kick you off for knowing who Joe Francis is. I just want him to get a fair trial. Id. Following the juror s public comments, Francis went on to tell the press that he did not believe that he was convicted due to his celebrity status, but because he did not personally attend the trial and because the jurors, who have small penises, were jealous of his large penis, which Francis insisted has been reported on widely in the media. Stephen Galloway, "Convicted Girls Gone Wild Mogul Joe Francis Breaks Silence: 'Retarded' Jury 'Should Be Shot Dead'," The Hollywood Reporter, May 22, 2013 (last visited May 27, "Paris to World -- I'm a Victim of Cruelty," TMZ, May 6, 2007 (last viewed May 1, John Gibeaut, Celebrity Justice, 91 ABA J. 42 (2005). 62 John Gibeaut, Celebrity Justice, 91 ABA J. 42 (2005).

20 263 [T]he phenomenon of prosecution by the press can go further than... assault on character that tends to poison the jury pool or the celebrity's career. It can also lead to [press]... unearthing additional evidence... adding private resources to the prosecution's already well-funded investigation. 63 Many attorneys still believe that the media essentially determines institutional decisions. 64 Others believe that allowing cameras into court alters the relationship among the media, the public, and the criminal justice system. 65 Powerful gossip blogs, like TMZ, may be the only media present at certain celebrity hearings. 66 The issue of celebrity crucifixion by the press was raised during the height 63 Julie Hilden, Celebrity Justice: Famous, Wealthy Criminal Defendants Can Hire High-Priced Lawyers, But Do They Also Face Disadvantages?, FIND LAW, Aug. 27, 2004 (last visited Feb. 21, Stehlin, Casenote: Is Open Voir Dire "A Good Thing"? ABC, Inc. V. Martha Stewartn1: The Second Circuit's Interpretation of First Amendment Rights During Jury Selection in High-Profile Celebrity Trials. John Gibeaut, Celebrity Justice, 91 ABA J. 42 (2005). 65 Stehlin, Casenote: Is Open Voir Dire "A Good Thing"? ABC, Inc. V. Martha Stewartn1: The Second Circuit's Interpretation of First Amendment Rights During Jury Selection in High-Profile Celebrity Trials. John Gibeaut, Celebrity Justice, 91 ABA J. 42 (2005). 66 TMZ.com (last visited May 1, 2013).

21 264 of Paris Hilton s legal troubles in After receiving a forty-five-day jail sentence for a reckless driving case, many bloggers opined that Hilton was the victim of celebrity justice. 68 Hilton is a young, wealthy, ostensibly attractive, European American woman. 69 Many traditional biases were in her favor for leniency. 70 During Simpson s trial, the live coverage and videos played on T.V. A large portion of the media coverage on Hilton s trial occurred online, and some coverage occurred on the kinds of celebrity blogs that many celebrities have described as cruel and mean. 71 When the media 67 Sharon Waxman, "Celebrity Justice Cuts Both Ways for Paris Hilton," THE NEW YORK TIMES, Jun. 9, 2007 (last visited Feb. 21, Sharon Waxman, "Celebrity Justice Cuts Both Ways for Paris Hilton," THE NEW YORK TIMES, Jun. 9, 2007 (last visited Feb. 21, Sharon Waxman, "Celebrity Justice Cuts Both Ways for Paris Hilton," THE NEW YORK TIMES, Jun. 9, 2007 (last visited Feb. 21, Chamberlain, Miller, and Jehl, 3 VAND. J. ENT. & TECH. L. 551, "Paris to TMZ Users, You've Hurt Me Bad," TMZ, Jul. 20, 2006 (last viewed on May 1, Christie D'Zurilla, "Khloe Kardashian calls out Perez Hilton as her 'personal bully'," LA Times, Oct. 20, 2010 (last visited Feb. 22, "Perez Hilton pledges to stop bullying celebrities," THE TELEGRAPH, Oct. 15, 2010 (last visited Feb

22 265 reported that her sentence was harsh, they were rendering a sophisticated analysis about jail procedures, median sentences, and judicial discretion. 72 Bloggers did not seem to specify frequently whether they meant that Hilton s sentence was harsh in comparison to others in or outside of her demographic. 73 In response to Hilton s comments to a gaggle of camera people, that she told the truth but felt that it was not enough because she was still treated unfairly, a timely TMZ poll showed that ninety-seven percent of respondents believed that Hilton received what she deserved. 74 Of the sentence, Hilton said that she did not deserve the sentence as it was "both cruel and unwarranted." 75 The poll did not identify why 22, Hilton-pledges-to-stop-bullying-celebrities.html). 72 Sharon Waxman, "Celebrity Justice Cuts Both Ways for Paris Hilton," THE NEW YORK TIMES, Jun. 9, 2007 (last visited Feb. 21, Sharon Waxman, "Celebrity Justice Cuts Both Ways for Paris Hilton," THE NEW YORK TIMES, Jun. 9, 2007 (last visited Feb. 21, "Paris to World -- I'm a Victim of Cruelty," TMZ, May 6, 2007 (last viewed May 1, Id.

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