Johnny Depp won the defamation case against his ex-wife, Amber Heard, in a US courtroom.
However, the Hollywood star in 2020 lost a UK defamation lawsuit against the newspaper The Sun.
This led to many reactions and discussions about why he lost the trial in the United Kingdom and won it in the United States of America.
Johnny Depp (Photo: Steve Helber/Pool/AP)
The reason, according to legal experts, may simply be due to the fact that Depp's action in the UK - which he lost - was decided by a judge, while his case in the United States was decided by a jury.
"The answer is simple," said George Freeman, executive director of the Media Law Resource Center. "It was up to the jury."
Depp won his three counts of defamation against his ex-wife and was awarded $15 million, a seven-person jury announced Wednesday. The jury also awarded Heard two million dollars.
Johnny Depp and Amber Heard (Photo: Getty Images)
Depp sued Heard in Fairfax, Virginia, in 2019 over an article published months earlier in The Washington PostHeard did not mention Depp by name in the article, but wrote that she was "a public figure who represented domestic abuse."
In 2020, Depp lost a similar case in the United Kingdom, in which he sued the tabloid The Sun because she called him an "abuser".
So some were surprised when Depp won the US case, given that plaintiffs here face a much higher bar to prove defamation of a public figure. Under US law, a plaintiff in a defamation lawsuit must prove that they were harmed by an entity acting with actual malice, meaning that they knew a defamatory statement was untrue when they made it.
Johnny Depp and Amber Heard (Photo: Getty Images)
Although Heard was not named in the British case, she testified over several days as a witness called by The Sun.
Although the Virginia case had a much higher standard to pass for Depp's team, "it didn't affect the outcome because essentially what you have is evidence that a jury believes that a British judge didn't accept, so that's where the difference lies. Unusually, not in the different legal frameworks."
This may explain why Depp lost out in the UK even though he was not required to prove that the 'abuser' label was false.
Depp then requested that the case be heard in Virginia rather than California, where he and Heard reside.
Heard, on the other hand, sought to have Depp's lawsuit dismissed, but failed.
The other difference between the two cases is the chaos that took place online outside of the courtroom.
While the UK case generated huge media coverage, the Virginia trial took it to another level. The trial was broadcast live, with millions of people tuning in and analyzing the testimony on social media. /Telegraph/
