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Waller v. Osbourne

District Court, M.D. Georgia (1991) | 763 F. Supp. 1144; 1991 U.S. Dist. LEXIS 6073; 1991 WL 76010

4 min read

TL;DR: Parents sued Ozzy Osbourne, alleging his song "Suicide Solution" caused their son's suicide via subliminal messages and incitement. The court granted summary judgment for the defendants, finding the song was protected speech under the First Amendment and contained no proven subliminal messages or incitement.

Legal Significance: This case reinforces the high bar for incitement claims against artistic works under the First Amendment. It establishes that unintelligible lyrics do not constitute unprotected "subliminal messages" and that abstract advocacy of harmful ideas in music does not meet the *Brandenburg* test for incitement.