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They might, for example, face bad publicity generated by an upheld complaint to the ASA.
But in terms of legal precedent, an upheld conviction against Valle would follow contemporary US justice's increasing and dangerous reliance on predictive policing.
She said: "An upheld complaint is a serious outcome for any editor and puts down a marker for future press behaviour... "The fact that breaches of the code can lead to public criticism means that editors have to consider the key ethical issues before publishing.
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It recently cleared a hurdle when a court upheld a contract with National Grid for purchase of half its electricity.
Last month, a judge upheld a prison sentence for a human rights advocate, Nabeel Rajab, who was convicted of inciting protests.
A court upheld a $1 million malpractice verdict this year, ending lengthy appeals by the hospital.
In California, a court upheld a ban on buttons in San Diego schools in 1996.
A court upheld a complaint from the Association Madrileña Del Taxi made earlier this month.
A conservative court, and a conservative justice, upheld a law passed and treasured by liberals.
Ohio banned the film, an action upheld by the Ohio Supreme Court.
In September of 1999 an appeal upheld the ruling.
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Justyna Jupowicz-Kozak
CEO of Professional Science Editing for Scientists @ prosciediting.com