The case of Frankie Rzucek v Alan Vinnicombe
Cohen Davis acted for Franklin “Frankie” Rzucek in his claim against Alan Vinnicombe, a UK based YouTuber who published a long series of videos about the murder of Mr Rzucek’s sister, Shanann Watts, and her two daughters. On 23 April 2026 the High Court handed down judgment. Mr Rzucek was awarded £40,000 in damages for defamation and an injunction restraining the defendant from repeating the allegations. The judgment is reported as Rzucek v Vinnicombe [2026] EWHC 946 (KB).
The case is a clear example of something we are asked about often: whether a person living abroad can take legal action in England against a UK based individual who is spreading harmful content online. The answer, as this case shows, is yes for defamation, with an important qualification for harassment that we explain below.
What the case was about
In August 2018 Shanann Watts, Mr Rzucek’s sister, was murdered in Colorado along with her two young daughters by her husband, Christopher Watts, who later pleaded guilty and was sentenced to life imprisonment. The case attracted enormous media and online interest around the world, including in the United Kingdom.
Alan Vinnicombe ran a YouTube channel called “Armchair Detective Blue”, with more than 79,000 subscribers, on which he posted at least 180 videos about the Watts case between 2018 and 2023. When Mr Rzucek set up a CrowdJustice page to fund legal action over online publications about his sister’s murder, Mr Vinnicombe, believing the action was aimed at him, responded in a series of videos. Mr Rzucek’s defamation claim focused on five of those videos, published between November 2021 and August 2022, which suggested that he was dishonestly raising money from the public and that he was himself engaged in harassment and other unlawful conduct.
How the case came to us
For a grieving family in the United States, the hardest part was finding anyone who could help. The people publishing about Shanann’s murder, and about her family, were in the United Kingdom, and US lawyers could do little about conduct on the other side of the Atlantic. The family began looking for a firm in England that understood both online abuse and the cross-border difficulties their situation raised.
They found us online. Having followed everything the family had already been through since Shanann’s death, and after speaking with the family, including Frankie’s mother, we agreed to take the case on. It was a matter that called for patience and persistence over several years, and we were glad to stand with the family through it.
With thanks
A case like this is never won by lawyers alone. We are grateful to counsel, Gervase de Wilde, who acted pro bono and whose submissions the judge singled out for their clarity. We thank the many people who supported Mr Rzucek and his family, including those who backed the CrowdJustice appeal that made the legal work possible. Most of all we acknowledge the courage of the family, who pursued this through years of proceedings in a foreign court while carrying a loss that no family should have to bear.
The outcome: £40,000 in damages and an injunction
The defendant’s defence and counterclaim were struck out at an earlier stage, and his application for permission to appeal was refused. The hearing before Dan Squires KC, sitting as a Deputy High Court Judge, was to decide what remedy Mr Rzucek should receive.
The court found that the five videos were seriously defamatory. They alleged dishonesty, including that Mr Rzucek was raising money from the public on a fraudulent basis, and that he had harassed the defendant and caused threats of violence to be made against him. The judge accepted that the videos were watched by a large audience, and that a majority, perhaps three quarters, of those views were within England and Wales, so likely more than 20,000 people in this jurisdiction.
The judge awarded £40,000 in general and aggravated damages. The award reflects the seriousness of the allegations, the scale of publication, the distress caused given the tragic context, and the fact that the defendant never apologised or retracted and repeated the allegations during the litigation. The judge also granted an injunction restraining the defendant from publishing the same or similar defamatory allegations again.
The harassment claim, and why it matters for overseas victims
Mr Rzucek also brought a claim for harassment under the Protection from Harassment Act 1997. On that claim the court reached a different conclusion, and the reason is important for anyone living outside the UK who is targeted by a UK based individual online.
The Protection from Harassment Act 1997 applies to England and Wales only. On the authorities the judge considered himself bound to follow, the tort of harassment is not complete unless the person is actually harassed within the jurisdiction. Because Mr Rzucek was in the United States throughout the relevant period, the court held it could not award a remedy for the past harassment, and declined to grant one.
The judge recognised that this may produce unsatisfactory results in an age of instant global communication, where a person can be targeted from one country while living in another, and he suggested that whether the law should be read more broadly is a question for a higher court. He also made clear that an overseas victim is not left without protection. A person who intends to travel to the UK and who fears the conduct will continue can seek an injunction for an “apprehended” breach of the Act.
The practical lesson is one we give clients regularly. Where a UK based person is publishing harmful material about someone overseas, defamation is often the stronger route, because the defamation claim is complete when the material is published here, wherever the claimant happens to live. Harassment can still be a powerful tool, but its reach across borders is more limited, and the strategy needs to be built accordingly from the outset.
When harassment can still lead to damages
It is important not to read this case too widely. The outcome on harassment turned on a specific fact, that Mr Rzucek was in the United States throughout the period of the conduct. The position can be very different where the victim has suffered the harassment while physically present in England and Wales.
Because harassment is about the effect on the victim, what matters is where the victim was when they experienced the abusive course of conduct. If a person is in the jurisdiction when they are harassed, even during a visit to the UK, the harassment is suffered here, and a claim under the Protection from Harassment Act 1997 can proceed and may attract damages. A person who is abroad but intends to travel to the UK, and who fears the conduct will continue, may also seek an injunction for an apprehended breach, as the judge in this case confirmed.
We deal with these cross-border jurisdiction questions regularly, and we discuss how they work, with examples, on our pages on cross-jurisdiction internet law for international clients and on harassment and disclosure injunctions against anonymous users. Whether a UK harassment claim is open to you depends on the detail of where you were, and when, so it is worth taking advice early.
Why the choice of claim and jurisdiction mattered
This case shows why the early strategic decisions in a cross border online abuse matter can decide the result. The defamation claim succeeded precisely because it does not depend on where the victim lives. The harassment claim, on the same facts, did not yield a separate remedy because of where the victim lives. Selecting the right cause of action, and understanding how the English courts treat jurisdiction for each of them, is the difference between a remedy and none.
We act for individuals and families in the United States and elsewhere who are being targeted online by people based in the United Kingdom. If you are outside the UK and someone here is defaming or harassing you, English law may give you a remedy that is not available, or is harder to obtain, in your home country.
How we prepare cases like this
Our firm is known for taking on complex cases involving online discovery, harassment and defamation. Before we take a complex case on, we carry out an initial assessment of the evidence and the law, to satisfy ourselves that the client has a reasonable prospect of success. Litigation of this kind takes a considerable investment of time and expertise, from preserving and analysing the evidence, to preparing a detailed statement of case, to pursuing the claim through to judgment where a settlement cannot be reached.
Where a case is funded through crowdfunding on a platform such as CrowdJustice, the money raised goes directly to the regulated law firm’s client account and can only be used to pay for actual legal work. No funds are received or handled by the client directly or indirectly.
Speak to us
If you are being targeted online, in the UK or from abroad, and you want to understand your options under English law, contact the Internet Law Centre for a confidential discussion.
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