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There are huge differences between UK and US media law - does this explain why more Americans are being accused of sexual harassment?

On 5 October, Harvey Weinstein was accused of sexual abuse and the dam broke.

Since then, dozens of well-known Americans have been accused of sexual misconduct of some kind. This isn't drip-drip. It's a flood.

The list includes film stars such as Kevin Spacey, politicians such as Roy Moore, and journalists such as Mark Halperin.

The deluge of allegations swelled this week, engulfing big media names.

While people in other countries have also been accused, the majority of cases are American.

One reason could be US media law and how it differs from other countries.

In the UK, there is a key point in libel law that explains a lot.

When someone sues, they don't have to prove the story is wrong.

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The publisher - for example, the newspaper or website - has to prove their story is right.

This means, before publishing, the media needs a water-tight case. To accuse someone of sexual misconduct, they would normally need proof (such as a recording) or a witness prepared to testify in court.

In cases of sexual misconduct, both things are hard to find.

There were, for example, rumours of Jimmy Savile's sexual abuse for years. Louis Theroux even asked Savile about them in 2000.

But the British media - worried about being sued - didn't publish. It wasn't until Savile died that ITV broke the story (in UK law, a dead person cannot be defamed).

You don't even need to name someone to be sued in the UK.

In 2012, BBC Newsnight wrongly linked Lord McAlpine to child sex abuse, without naming him.

He sued and within 13 days won £185,000 in damages.

Defamation in the UK - the main defences

Truth

Honest opinion

Protected by privilege (for example, court reports are protected)

Published on a matter of public interest

In the US, it's far harder to sue for libel. The reason is 226 years old, but as relevant as ever.

The first amendment to the US constitution - adopted in 1791 - protects freedom of speech and freedom of the press.

It means American media law is "radically different" to the UK, says Stuart Karle, a professor at Columbia Journalism School in New York and former general counsel for the Wall Street Journal.

"In the US, the burden is on the plaintiff - the person alleging that he or she has been defamed - to prove the statement is false," he says.

So - compared to the UK - the burden of proof is flipped. Americans are less likely to sue, so US media are more likely to break the story.

Indeed, a New York Times editorial in May said "hardly anyone jousts with the (New York) Times when it comes to formally asserting libel".

And - for celebrities - there's another hurdle to clear when suing in the US.

When a public official (such as a government employee) or public figure (such as a celebrity) sues for libel, they must prove "actual malice".

"Actual malice basically means the journalist lied," says Professor Karle.

"Either the journalist published a story they knew was false - or they acted with reckless disregard over whether it was true or false.

"That basically means - you lied."

But - despite the bar being higher - it doesn't mean American media has carte blanche. And, when they do get it wrong, it can cost millions of dollars.

In 2014, Rolling Stone magazine covered an alleged gang rape at the University of Virginia in 2012.

The story was retracted in 2015 and a university official - who handled sexual assault cases - sued for defamation. She was awarded $3m in damages.

Further back, a prosecutor sued the Philadelphia Inquirer over articles published in 1973. He won $34m.

"Sometimes you hear 'in the United States, reputation isn't valued'," says Professor Karle.

"But the US laws are highly protective of reputation. The damages can be massive - far, far greater than one could get in the UK.

"So you have more (defamation) cases in the UK and more stories that aren't published or broadcast.

"But in the US, if a plaintiff wins, the potential damages are in the millions - or tens of millions."

For this reason - and for reasons of good journalism - American media often goes to great lengths to verify accusations.

In their recent story about television presenter Charlie Rose, the Washington Post spoke to eight women - three of them on the record.

In breaking the story about comedian Louis CK, the New York Times reported accusations from five women - four of them named.

And - in an article about New York Times reporter Glenn Thrush - Vox writer Laura McGann recounted her own experience, interviewed three other women, and spoke to 40 people in the wider media.

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Which system is better - the UK or the US - depends on your point of view.

If you've been wrongly accused, you may yearn for the British system - where publishing is riskier.

If you're a victim, you may prefer the US system - where the constitution protects freedom of speech.

Either way, the effect is clear.

The US has a flood of cases. In the UK, it remains drip-drip.

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Why so many sexual harassment cases in US, not UK?

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There are huge differences between UK and US media law - does this explain why more Americans are being accused of sexual harassment? On 5 October, Harvey Weinstein was accused of sexual abuse and the dam broke. Since then, dozens of well-known Americans have been accused of sexual misconduct of some kind.

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Lowering harmful alcohol consumption in Scotland

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Lowering harmful alcohol consumption in Scotland

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With cheap prices of alcohol, "binge drinking" is a serious issue in Scotland. People can afford to buy more high-strength alcoholic drinks and this has led to the 1,265 alcohol-related deaths in the past year alone. It has been estimated that "a minimum unit price of 50p would cut alcohol-related deaths by 392 and hospital admissions by 8,254 over the first five years of the policy." Five years in which this legislation was tied up with the Scottish Whisky Association.

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From the section Scotland politics

Scotland will introduce minimum pricing for alcohol on 1 May next year, the Scottish government has announced.

The move will raise the cost of the strongest, cheapest alcohol by setting a minimum price per unit.

Health Secretary Shona Robison told MSPs that she expected the price to be set at 50p-per-unit, but this will be subject to a consultation.

She said the measure was needed to tackle the "devastation" caused by cheap, high-strength alcohol.

The 50p-per-unit minimum would raise the price of the cheapest bottle of red wine (9.4 units of alcohol) to £4.69, while a four-pack of 500ml cans of 4% lager (8 units) would cost at least £4 and a 70cl bottle of whisky (28 units of alcohol) could not be sold for less than £14.

Key weapon

Normal strength cider (5% ABV) would cost at least £2.50 a litre but a super-strength version (7.5% ABV) would have to cost a minimum of £3.75 for a litre.

But it would leave more expensive drinks unaffected, and is unlikely to impact on sales in pubs and clubs.

The Scottish government views minimum pricing as a key weapon in the battle against binge drinking, with people in Scotland said to buy 20% more alcohol on average than those in England and Wales.

Alcohol Focus Scotland research from last year suggested that the maximum recommended weekly intake of alcohol - 14 units - could be bought for just £2.52.

BBC

The Scottish Parliament passed the minimum pricing legislation five years ago but it was tied up in a legal challenge by the Scotch Whisky Association until last week, when the Supreme Court ruled that it did not breach EU law.

Minimum pricing has been broadly welcomed by health bodies and alcohol awareness groups, who say it will target the kind of drinking that leads to the greatest harm.

There were 1,265 alcohol-related deaths in Scotland last year, an increase of 10% on 2015 - figures which Ms Robison described as "completely unacceptable".

Speaking in the Scottish Parliament, she said: "Behind every one of these statistics is a person, a family and a community.

"With alcohol on sale today at just 18p a unit, we have to act to tackle the scourge of cheap, high-strength drink that causes so much damage."

Ms Robison said research had shown that a minimum unit price of 50p would cut alcohol-related deaths by 392 and hospital admissions by 8,254 over the first five years of the policy.

She added: "I anticipate setting the minimum unit price at 50p per unit. We now want to hear from retailers, representative bodies and Licensing Standards Officers about the practicalities of implementation."

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From the section Scotland politics Scotland will introduce minimum pricing for alcohol on 1 May next year, the Scottish government has announced. The move will raise the cost of the strongest, cheapest alcohol by setting a minimum price per unit.