page_title: Bare-faced Messiah
section_title: Legal disputes
hierarchical_section_title: Bare-faced Messiah / Reaction from Hubbard's followers / Legal disputes
caption_attribution_description: English: Copyright 2004 by Gerry Armstrong and Caroline Letkeman. Caroline took this photo in Chilliwack, B.C. on July 5, 2004. Originally webbed on Gerry's contact page: http://www.gerryarmstrong.org/50grand/contact.html
context_page_description: Bare-faced Messiah: The True Story of L. Ron Hubbard is a posthumous biography of Scientology founder L. Ron Hubbard by British journalist Russell Miller. First published in the United Kingdom on 26 October 1987, the book takes a critical perspective, challenging the Church of Scientology's account of Hubbard's life and work. It quotes extensively from official documents acquired using the Freedom of Information Act and from Hubbard's personal papers, which were obtained via a defector from Scientology. It was also published in Australia, Canada and the United States.
  The Church of Scientology strongly opposed the book's publication. The organization was accused of organising a smear and harassment campaign against Miller and his publisher, though it strenuously denied this accusation, and a private investigator involved in the campaign denied that the organization was his client. However, a leak of internal Scientology documents to the press in 1990 disclosed many details of the campaign.
context_section_description: The Church of Scientology and related entities sought injunctions against the book's publication, claiming copyright infringement of Hubbard's private documents. They threatened to sue in as many as fifty countries, adopting a strategy that the University of Pennsylvania's Professor Paul K. Saint-Amour has described as "an international parade of litigation" and "whack-a-mole legal proceedings". Much of the dispute centred on the plaintiffs' argument that the actions of former Scientology archivist Gerry Armstrong in providing Miller with unpublished materials (whether directly or indirectly) were a breach of his duty of confidence to the Church, and that the use of excerpts from this material violated copyrights owned by Hubbard's estate. Miller later noted that the plaintiffs did not attempt to dispute the facts of the book in court which, he said, was a pity as he had been looking forward to defending his meticulous research.
caption: Gerry Armstrong, the former Scientology archivist whose disclosure of Hubbard's unpublished writings became a central issue in the litigation over Bare-faced Messiah.
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