Poland

By Paige Vaughn

Introduction

Polish Flag            Eastern Europe’s Poland has had many significant changes to its government in the last half century, going from a communist country to a free republic within the last quarter century. Poland has an independent state for less than 100 years, and even after its creation it was constantly reshaped and redefined until the early 1990s.

Every year Reporters Without Borders develops a “World Press Freedom Index,” to rank and compare the world’s countries’ commitment to freedom of expression. Over time, Poland’s ranking for free press and free speech has risen and continues to rise, according to this specific organization. In 2013, Poland ranked 22, rising from 32 in 2010 and 57 in 2007.

The numbers from Freedom House, another organization who analyses freedoms and protection in countries, appear differently. In the 2013 ranking of free press, on a scale of 1-100 (1 being completely free and 100 being not free), Poland scored a 26 out of 100. In 2007, Poland was reported 18, indicating press and speech were less restrictive in the past and more so now.

Even with yearly changes and discrepancies in numbers, through Poland’s history and current events one can see a huge change in freedoms allowed for Poles.

Historical Background

            As mentioned previously, Poland’s government has changed dramatically. In the early 1900s, when World War I started, Poland was not an independent state, as its land transitioned through possession to Prussia, then to Russia, and lastly to Hapsburg Empire of Germany (including Austria-Hungary). [a] After over 120 years, the desecration of the German, Russian and Austrian rule led to the declaration of Poland as its own state in the Treaty of Versailles. With uncertain borders, Polish chief of state, Joseph Pilsudski, tried to expand his territories into Ukraine. He believed this would build a buffer against further expansion of surrounding areas.

Strife continued in Eastern Europe when Adolf Hitler’s Nazi regime occupied Poland, leading it to be further divided between Germany and the Soviet Union. During the 1940s and World War II, Nazi Germany hosted extermination camps in German Poland where around 3,000,000 Poles were executed. In the other captured area of Poland, Joseph Stalin also ordered the deaths of 20,000 Polish citizens. [b] After the fall of Nazi Germany and Hitler’s rule, Stalin refused to return Polish lands. Poland’s Allies at the time included Great Britain and Britain. Regained Polish lands amounted to a 20 percent loss of original Poland. In 1945, with no input from Poland, Great Britain’s Winston Churchill and the U.S. had outlined Polish bordered where they stand today.

Between the 1950s and the late 1980s, Poland was socialist and communist, as a satellite state of the Soviet Unison. The movement between these two governments was slow and was mainly under the rule of communist Wladyslaw Gomulka. [c] With the fall of the Soviet Union, the communist government in Poland fells, and in its place the social democracy of the Republic of Poland rose to power in the 1990s.

Poland today is considered a parliamentary republic, governed by a constitution and three branches of government: an executive branch, a parliament and a judicial branch. The executive branch of government consists of a prime minister, a cabinet, and a president. The judicial branch is composed of courts of law and several specific courts, such as the Constitutional Tribunal. “The Tribunal monitors and rules on matters alleged to be unconstitutional, protects the rights of individuals, and interprets the laws passed by the National Assembly with respect to rights defined by the Constitution.” [d]

Poles refer to their country as a “republic of many nations,” where their culture and way of life is influenced by its many occupations and surrounding countries. Poland is bordered by Germany to the west, the Czech Republic and Slovakia to the south, and Ukraine to the east. Currently their population 38.2 million and is considered the thirty-fourth most populated country in the world. [e] 97 percent of the population is composed of Polish people; Silesians represent 1.1 percent, and Germans and Ukrainians 0.3 percent. Contrary to popular belief of a rural lifestyle, 60 percent of Poles live in urban areas. [f] Around 95 percent of Poles practice Roman Catholicism, with 40 dioceses and 13 Latin archdioceses. [g] 

Free Speech

Past

By definition, communism is an economic system based on public ownership of property and control of the methods of production. Communist governments own the jobs, the means, and the futures of its people. With this structure in place, the central government is in direct control of most, if not all, means of mass media. With this power, governments try to control public opinion and maintain support for communism through the population.

Poland’s rocky political climate has had a dramatic effect on its development of free speech and free press. Poland’s path toward democracy is directly intertwined with its path towards amendable freedoms, with freedom of speech appearing first, then freedom of the press. The People’s Republic of Poland, as mentioned previously, was a communist state until the 1990s.  Freedom of expression has nonexistent in Poland, with livelihood and personhood controlled by the government. This was especially true during its occupation of Stalin and the Nazi regime. An extensive number of Poles were discriminated against because of ethnicity, without having to speak against the government, and in turn murdered in concentration camps. Stalin’s mass murders were focused on Polish elite and wealthy, who had influence necessary to possibly derail political plans. This murder limited the Polish elite’s possible vocal or symbolic disagreement with incoming rulers or parties. Those who weren’t killed were imprisoned for differences in political opinion, such as speaking against the government or rallying support for a western style of governing.

A turning point in Polish history began in the mid 1950s after Stalin died. A social movement occurred in 1956, named Polish October, also known as Gomulka’s thaw, relating to aforementioned Polish Wladyslaw Gomulka. This movement was the transformation from currently totalitarianism from the Soviet Union, into a more localized communism, an imagined “Polish road to socialism”. [h] In this “thaw” of “Cold” government, the control would be originating from Poland, not from another country. This change came about through conversation surrounding Stalin’s crimes and the Soviet’s place in Polish government altogether. After rallies and protesting, Gomulka was elected as the First Secretary of the Polish Workers’ Party and later Polish United Workers’ Party, placing him at the top of the Polish government system. “The elevation of Gomulka to first secretary marked a milestone in the history of communist Poland. Most importantly, it was the first time that popular opinion had influenced a change at the top of any communist government.” [i] This monumental occurrence appears to be the catalyst for spoken and written freedom in Poland, even if it has not become a democracy yet. Under Gomulka, the gradual process of having an opinion and not automatically being punished for contrasting ideals is underway. Under his leadership he promised private ownership, decreased censorship, freeing political prisoners, a lack of religious preference in the government, among other things. This shows the beginning of Polish commitment to freedom of speech and press.

With confidence building around the exchange of ideas, the 1980s brought about the Solidarity movement. This social movement originated as a labor issue in a shipyard, but turned into a strike against communist government. The movement gained millions of followers and the support of the Pope towards a “republic” or a “People’s Poland.”[j] Communism was put on its last leg, under the martial law of Wojciech Jaruzelski, where all expression of opposition was to be silenced. This is a moment in Polish history where the government has a complete disregard and lack of commitment for free speech. This was not the case, the support for a free Poland continued. By late 1988,  “unofficial opposition groups were flourishing, and Solidarity, still nominally illegal, operated quite openly.” [k] This social unrest and expression caught the public eye. Poles’ voices, despite the government and martial law, were seeking to be heard to overcome the government and economic depression Poland faced. The international systems of governments were conscious of the struggles of Poland, but no real aide was given until the end of their struggle with communism.

Present

The installation of democracy in Poland in 1990 was, for obvious reasons, the main reason for the introduction of freedom of expression and press in Poland. The freedom of speech was first written into Polish law in 1992 through the Little Constitution, the predecessor to today’s Polish Constitution, which was effective 1997. The Little Constitution declared Poland as a parliamentary system. This freedom of speech clause allowed Poles “to hold opinions and to receive and impart information and ideas without interference by public authority and regardless of frontiers.”[l]

As shown in the introduction, Poland is rated very highly for its free speech. It is not simply enough to have a right written into law; it must to upheld and practiced. If Poland writes that it country allows free speech, it must be prepared to hear and see speech it doesn’t like. If it only expects positive and supportive speech, Poland is aligning itself with beliefs of its communist days.

One of the most controversial laws Poland upholds is banning offenses towards religious feelings or sentiment. The law is most readily used against artists, who thrive under freedom of expression. The protection of the majority’s Catholic believes stemmed from censorship against its attempted press. Poland has no official religious, but its population is mostly homogeneously Catholic. Article 196 of the Penal code reads, “anyone found guilty of offending religious feelings through public calumny of an object or place of worship is liable to a fine, restriction of liberty or a maximum two year prison sentence.[m]

International standards on freedom of expression are violated with this act, because of how vague “offending feelings” is and how sweeping the legal standing on this can be, it is dangerous to free speech.

Recent events have led to landmark judgments surrounding this law. In 2007, musician Adam Darski was arrested by Polish police for offending Catholics at a show. During his concert, he described the Catholic Church as “the most murderous cult on the planet,” after tearing a Bible. In 2012, the Polish Supreme Court was examining his intent, and ultimately concluded it was artistic expression, not purposeful offense. The supreme court was asked how Darski could be “offending religious feelings” if most of Behemoth’s fans expected theatrical sacrilege, since he’d been preforming similar acts for two years previously, building a reputation around this. [n] The fact that the case was dismissed displays a growing realization and commitment to free speech.

Another instance of offending religious feeling comes through in the 2012 fining for Polish pop star Dorota Rabczewska for discrediting the bible. According the Associated Press in a 2009 interview, “Rabczewska said she doubted the Christian holy book because it’s hard to believe in something that was written by someone drunk on wine and smoking some herbs.” [o] At first it can be questioned why she did not face jail time, like Darski, but when the fact that she is listed as one of the ten most influential women in the country by CNN, it become clear her fame caused her to have a lesser charge. This continued dispute over expressive and opinionated speech shows that Poland still must adapt to be completely open to free speech.

Freedom Press

Past

Freedom of press grew from the same roots as the freedom of expression. There were no privately owned press mediums, “political control of the media was…total…and complete. The activities of all the different media were coordinate and subordinated to the goals defined by the leadership.”[p] Political opposition did not exist prior to Gomulka. The government-owned mediums did not include westernized talk radio, no entertainment TV programming and no discussion of ideas in paper.

After the communist thaw of Gomulka’s rule, leaps and bounds are made for free press in Poland after the Solidarity movement, beginning in the late 1980s and early 1990s. According to author Colin Sparks, there was pre-adaption to the media before a democratic society was determined, or rather installed by the Axis Powers. [q] In Spark’s studies there had been prevalent characteristics of a commercialized broadcasting system appearing in Poland. The seeds that were planted during Polish October and through Solidarity were appearing through the realization that mass media is powerful. As an upcoming power, changes began to happen in journalism to develop ethics, financing private channels, and open-mindedness to other cultural influences, like the western world.

The “roundtable” discussions started by Jaruzelski included discussions about the freedom of media. The Solidarity party wanted social control over media, while the communist leaders wanted to give Poles some input and maintain overall control of media. The proposal of a three-stage plan by Solidarity was a major historic move for Polish resistance. The plan included rules about fair and equal air time for political parties, giving over two major TV and radio stations to the Poles, and to have a non-governmental body protect and supervise such channels. [r] This of course was refused, and Poles were given the condolence prize of censored programs, once a week, for thirty minutes. This provides evidence once more of the attempt for freedoms by the people and a small (but growing) commitment from the government.

Though Poland had its issues with an un-free press, it offered one of the most diverse media communities in the Soviet bloc, with 56 daily newspapers, 595 magazines, 4 radio stations and 2 television channels. The government, showing propaganda, controlled most of these channels but the upkeep of such channels was uncommon in soviet-controlled countries. During this period weekly newsletter were also popular. Communist leaders allowed for these niche publications to win some favor in Poland. They wanted many different specific topics covered in the weeklies to make Poles feel like every person was very different, not sharing common interest or goals. By not realizing common goals and the support for a goal, such as anti-communism, there is less risk for upheaval. “Censors working with the weeklies, it was difficult at best…rules that held for all media were sometimes bent for these journals in recognition of their intellectual tastes…this did not mean they were above censorship.”[s]

Censorship across these channels was common practice in socialist and communist Poland.  In publications that tried to communicate to Poles about foreign affairs, strict prior approval is needed before printing. For example, Poles were shielded from the reality of Soviet allies and countries with which it held or might hold trade agreements. The law in 1976 stated, “do not use the term “military dictatorship” or other terms, such as “guerilla,” to refer to states with which we maintain diplomatic relations.” This specifically came into play with Iran, as Poland was dependent on them for oil. “All material (including the slightest mention, photographs, etc.) relating to the past and present conditions of Iran or the Shah should be approved by the administration.” [t] This censorship did not lead to an inform public, and without an informed public, Poles lack awareness of issues that might effect them – like relations with controversial Iran.

Free press is meant to inform and serve as a catalyst for correcting widespread grievances. In 1976, censorship is used once again to keep the public unknowledgeable. There had been a large increase in price increases and inflation surrounding daily Polish needs, and the causes remained unannounced by the government purposely. Polish journalists felt like this was in desperate need of research and discussion. Marta Wesolowska attempted to report this news, but even with extreme effort of her paper’s editorial board, the censorship could not be overturned. The freedom to be an informed citizen is desirable, even an unalienable right in some countries, but most certainly being aware of matters that effect every day needs is crucial. [u]

The press of religious bodies was also censored. There was a huge conflict between religion (and what it entails) and a communist regime. Censorship aimed to complicate the Catholic Church’s mission and recruitment by limiting parish bulletins and other promotional or evangelical material. No print was to be published that suggested nonbelief, recognized in Marxist documents, was better than religious. [v]

In all these areas of press and more, communist and socialist censors tried to maintain common and controlled messages that aligned with governmental goals. Toward the end of socialist and communist rule in Roland, small leaps are make with some creativity and diversity in intellectual topics being allowed to print. Even with this, there is a long way for press to go to be considered free. “Ultimately censors attempted to black out enough criticism and discussion to create an illusion of cultural development and freedom when neither existed in Poland.”[w]

Present

Polish Parliament abolished the censorship in 1990. Current Polish law states that the freedom of speech means the freedom of press. Poland’s most significant attempt to protect this right was allowing the non-governmental Polish Journalists Association to exist. The Association’s main aim is to protect the journalists’ freedom to find sources of information, to strengthen free press and to guarantee just proceedings surrounding this right. The PJA “provides journalists with the free consultation and legal help in conflict situations, documents journalistic conflicts, influences public administration dealing with the press, especially in the area of reacting on the express criticism. It creates centers protecting the free press in the countries of East-Central Europe.”[x]

Poland has more than 5,400 national and local newspapers dailies, weeklies, and specialists papers.  The publications include stories about events in Poland and the region’s political, social and cultural life, as well as niche trade publications. The freedom given is astronomically more than in the previous years. Journalism is still met with some resistance, with a number of libel cases appearing in courts.
An April 2013 story about transport minister Slawomir Nowak’s trustworthiness as a public official was published in the popular magazine Wprost. The article discussed beliefs that he favored businessmen whom he was friendly with and giving them contracts because of their friendship. He was also accused of being bribed by paid initiations to upper class events by these corporate friends/entities. Nowak filed a libel suit against the paper for damages of 7 million euros, an amount that would bankrupt the paper. “We are particularly worried by the size of the damages sought by Nowak,” Reporters Without Borders said. “Suing for this amount of money is clearly intended to intimidate. He is using the law to impose censorship by threatening the magazine’s financial survival. No publisher in Poland or anywhere else in Europe would be able to pay such a disproportionate amount.”[y] In a free press society, public officials, as public figures, are automatically more exposed to criticism of the press. By a public official committing an attempt at intimidation, they are violating the very foundation their career is built on.
A Gazeta Wyborcza writer, Jacek Brzuszkiewicz, was sued for libel in 2007 “over a series of articles in 2003 in which he criticized the verdict issued in a dispute between the residents of a public housing project and the owner of a laundry who used toxic products.”[z] The judge who decided the case was the complainant, claiming damages of 1,300 euros. The penalty of these charges were steep compared to the action, and with such financial threats, this kind of civil case may threaten political discussion. Polish law currently allows for prison sentences of journalists under article 212.2.
Even when the injustice of article 212 is brought to light, it is still used to hurt journalists. Andrzej Marek, the editor of the weekly Wiesci Polickie, was sentenced to three months in prison for such an instance. He allegedly libeled a city official in the 2001 article “Encouraging sharp practices.” [aa] The court rules again Marek, and because Marek exhausted all of his judicial options within the Polish government, he had to appeal to European Court of Human Rights in Strasbourg. Judgments like this make it difficult to be opinionated in the press, let alone allow the public to evaluate laws for disagreement and improvement.
With judicial cases arising over such issues, it makes one think that publically Poland is a relentless advocate of free press, but privately it gives off the impression of subtle oppression.

Critical Comparison
Speech

Before the U.S. had its constitution, it also had a journey from oppression to freedom. As colonies under Great Britain, the Unites States were under autonomous rule of tyranny, which speech against the government being unarguably punished. A big difference is that once the States were united, a constitution was developed, and a bill of unalienable rights were formed, Americans defended free speech to the best of their ability. Where as, Poland has limited itself in the past, even after its independence, and continues to do so in some degree.

In theory, current day Poland and current day United States share a similar government, both being Republics. They both have constitutions and they both have a freedom of expression section of their constitutions dealing with freedom of speech and press. Poland is actually rated above the U.S. in its free speech ranking, at 32, compared to Poland’s 22, but the U.S. justice system currently seems to offer more unalienable protections.

In Poland’s case with Adam Darski, he was arrested for tearing the Bible and offending religious feelings of his audience. A similar case was argued in the United States just a few years earlier in 2003 in Virginia v. Black, where Barry Black, Richard Elliott, and Jonathan O’Mara were convicted for cross-burning as harmful speech and intent to intimidate.  The three men violated a Virginia statute that prohibits cross burning, and specifies that “any such burning…shall be prima facie evidence of an intent to intimidate a person or group.” The cross is a known symbol of Christianity; much like the bible is to Christianity and Catholicism. The Supreme ruled in favor of Black, stating the statue was unconstitutional. The majority decision read “a state may choose to prohibit only those forms of intimidation that are most likely to inspire fear of bodily harm.” It could also be said that the fact fire, which is universally considered dangerous, was involved in this case, heightening the likeliness for intimidation. In Poland, a bible was being destroyed, without evidence that the means of destruction didn’t threaten anyone’s safety. This shows that the case was purely based on Darski offending the audience’s beliefs, not safety.
In comparison to Dorota Rabczewska’s fine for discrediting the bible, the United States Supreme Court hosted debate over the constitutionalism of Snyder v. Phelps. The case is based on the Phelps’ family Westboro Baptist Church protesting the funeral of Snyder’s late son, who had died while serving in Iraq with the United States Military. Phelps was charged with causing emotional distress on Snyder and his family with offensive comments pertaining to the late son’s sexuality and his afterlife. In this case, it was declared that emotional distress causes by public speech does not hold the speaker liable. The court found in favor of Phelps, though it offended the justices and was considered outrageous speech. The one dissenting opinion came from Justice Alito, saying, “Our profound national commitment to free and open debate is not a license for the vicious verbal assault that occurred in this case.” In terms of Rabczewska’s free speech issue, she was publically talking about her personal opinion of the bible and it offended Poles because of the mostly homogeneous religion of the country. Since Poland and United States have significant similarities in terms of government structure and stance on free expression, one can use the fact that, like Snyder v. Phelps, no Poles were coerced into reading Rabczewska’s opinion, therefore she shouldn’t be liable for religious offense taken.

Press

Both countries have obviously grown in their regard for the public to be informed through the press. When looking into the past, Poland hid political realties about other countries for governmental interest by censoring the press from using negative labels about hostile countries at the time, like Iran, even though the public had a right to be informed. The U.S. also committed similar injustices to citizens through New York Times Co. v. United States in the 1970s. President Richard Nixon attempted to exercise prior restraint to stop the publication of the classified Pentagon Papers by one of the most popular publications, New York Times. The court rules in favor of the NYT on the basis that government didn’t shown significant reason to censor the press. Though the censorship was not successful, the release of these documents showed that U.S. government had been hiding details surrounding the Vietnam War (a national and international event).  The United States has grown from this type of deceit, but still continues to develop its commitment to first amendment protections.

The 2013 libel case surrounding popular magazine Wprost and transport minister Slawomir Nowak’s trustworthiness as a public official represented an attempt of media intimidation through monetary threats by a government employee. Similar circumstance arose for the New York Times once again, finding itself in the midst of a landmark decision surrounding free press. New York Times Co. v. Sullivan was a SCOTUS case about the publication of a full-page ad soliciting funds for the defense of civil rights activist Martin Luther King Jr. in his efforts to end discrimination in the U.S. The ad was said to falsely represent the Alabama police and in particular, one of its supervisors by association, L. B. Sullivan. Sullivan was suing for damages of $500,000, a sum that would equal $3,965,895 today. This excessive compensatory demand for indirect alleged libel was be seen as excessive, with the power to damage even a large paper like the New York Times. The court ruled unanimously in favor of the Times, saying “the First Amendment protects the publication of all statements, even false ones, about the conduct of public officials except when statements are made with actual malice (with knowledge that they are false or in reckless disregard of their truth or falsity).” The courts protected the press against intimidation. To the knowledge of the Times, the information was not purposely false.  If Poland had the same standards for truly free press, they would have also seen the information given by Wprost was believed to be true, and that as a public figure and employee of the government, Nowak had a higher risk of being scrutinized.

Andrzej Marek criticized a city official in Wiesci Polickie in his analysis of the official “sharp practices,” and he was arrested for libel. This government employee, as mentioned before, is automatically at a higher risk of being scrutinized, because they are a city official. Marek was expressing his opinion on a law and was punished because of it, because the government allows for the jailing of journalist. It can be assumed that this is very far away from the concept of a free press. A similar situation is currently under way in the United States, where a Nashville General Sessions judge claims a local TV news station involving him were not only false, but also retaliatory in nature. He is pursuing a lawsuit because of this against WTVF-Channel 5 for misrepresenting the judge out of context. “He is seeking unspecified compensatory and punitive damages, as well as the retraction of what he believes were “defamatory and libelous statements” included in stories the station.”[bb] The news station believes that they did not do what they are accused of, and do not wish to retract. If the station did so, it might feel as if they are swayed by displeased public figures. The case is yet to be argued, but using the SCOTUS’ past judgments as precedence, if they news station did not knowingly air false or malicious statements, they may not be sued for libel. If it were to turn out this way, the U.S. commitment to freedom of speech would again be demonstrated.

Conclusion

Poland’s ruling constitution contains a free speech clause, which is revolutionary for its communist, anti-expressionist past. The constitution’s explanation of free speech also includes that press is included in this protection, making it easier to compare rights in Poland versus in the United States. There are certain clauses and articles that forbid things that allowed in the United States, like its laws on blasphemy and religious offence, as explained above. Poland’s defense of free speech rights, though present, must still need to be defended and molded. This isn’t to say Poland’s overall goal is to have restricted speech, but because of the age of their democratic government, progress and adjustments are needed to establish stronger protections.

The United States’ past with tyranny instilled the undeniable right for citizens to express themselves without fear of persecution, emphasized even more by the fact that freedom of speech is the very first demand in the country’s ruling document.  This has given the U.S. more time to develop and cultivated protected expression. With the common alias of the press as the “Fourth Estate,” under the assumption the other three estates are the U.S. branches of government, emphasizes the realization that the press, and its checking of the government, is just as important as the other branches of government. The view of the constitution as a living document has also contributed to varied interpretations and the continued success of the laws stated, as it is designed to evolve with the times. The first amendment covers all possible forms of self-expression: freedom of speech, freedom of the press, freedom of religion, right to assemble, and right to partition. With “all the bases covered,” the United States can offer judgments over any disagreement or question of self-expression, which is more than Poland can do thus far in time.

[a, b] PBS: The Struggle for Poland (http://www.pbs.org/behindcloseddoors/in-depth/struggle-poland.html)

[c] Poland: The Historical Setting

[d] Poland: Politics, government and taxation

[e] Poland Website

[f] World Fact Book

[g] Religious Life (http://en.poland.gov.pl/Churches,and,Religious,Life,in,Poland,397.html)

[h] Glenn E. Curtis, ed. Poland: A Country Study. 1992. Print.

[i] Glenn E. Curtis, ed. Poland: A Country Study. 1992. Print.

[j] Glenn E. Curtis, ed. Poland: A Country Study. 1992. Print..

[k] Glenn E. Curtis, ed. Poland: A Country Study. 1992. Print.

[l] “Freedom of Speech and the Right to Choose”

[m] The Impact of Blasphemy Laws on Human Rights – EBOOK 

[n] “Polish singer faces two years in jail over Bible-tearing stunt” 

[o] “Polish Superstar Dorota Rabczewska Fined for Bible Blasphemy” 

[p] Sparks, Colin, and Anna Reading. Communism, Capitalism, and the Mass Media. Pg. 17 London: SAGE Publications, 1998. Print.

[q] Sparks, Colin, and Anna Reading. Communism, Capitalism, and the Mass Media. Pg. 56-57. London: SAGE Publications, 1998. Print.

[r] Sparks, Colin, and Anna Reading. Communism, Capitalism, and the Mass Media. Pg. 97 London: SAGE Publications, 1998. Print.

[s] Curry, Jane Leftwich. The Black Book of Polish Censorship. Pg. 27 New York: Vintage, 1984. Print.

[t] Curry, Jane Leftwich. The Black Book of Polish Censorship. Pg. 125 New York: Vintage, 1984. Print.

[u] Curry, Jane Leftwich. The Black Book of Polish Censorship.  Pg. 156 New York: Vintage, 1984. Print.

[v] Curry, Jane Leftwich. The Black Book of Polish Censorship.  Pg. 315 New York: Vintage, 1984. Print.

[w] Curry, Jane Leftwich. The Black Book of Polish Censorship.  Pg. 414 New York: Vintage, 1984. Print.

[x] “Freedom of Speech and the Right to Choose “ 

[y] GOVERNMENT MINISTERS TRY TO INTIMIDATE POLISH MEDIA 

[z] GOVERNMENT URGED TO AMEND LAWS THAT RESTRICT PRESS FREEDOM

[aa] EDITOR TOLD HE WILL HAVE TO SERVE THREE-MONTH PRISON SENTENCE 

[bb] Judge files libel lawsuit against WTVF-Channel 5, reporter

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