Russell Miller had been an investigative journalist for the Sunday Times and had written well-received biographies of Hugh Hefner ( Bunny, published in 1984) and J. Courts in the UK and Canada took an opposite view, allowing publication of Bare-faced Messiah in the public interest. Supreme Court's decision to let a lower court's ruling stand, denying fair use protection for the book's use of unpublished sources, set a precedent favouring copyright protection of unpublished material over biographers' freedom of speech. The Church and related corporate entities attempted to prevent the book's publication in court, resulting in cases that reached the Supreme Court of the United States, the Court of Appeal of England and Wales and the Federal Court of Canada. However, a leak of internal Church documents to the press in 1990 disclosed many details of the campaign.
The Church 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 Church was his client. The Church of Scientology strongly opposed the book's publication.
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