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Denial (Movie)

Found in: social studies; 9-12

In 1993, Deborah Lipstadt, an American historian, published Denying the Holocaust, in which she criticized claims made by Holocaust denier David Irving. In 1996, Irving sued Lipstadt and her publisher for libel in a UK court. This was a strategic decision. Unlike libel cases in the US, English law puts the burden of proof on the defendant rather than the plaintiff. Denial (2016) (111 minutes) is not the typical court drama. Don’t expect thrilling last minutes revelations. You can expect strategy. Much of the movie takes place outside the courtroom: in restaurants, hotel rooms, judges’ chambers, and law offices, as well as at Auschwitz. It presents a personal view of a very different legal system and the compromises honorable people make to achieve a just outcome. The movie could be used in grade 9-12 history, pre-law, and journalism classes to introduce questions of free speech, the Holocaust, Holocaust denial, evidence, fact & opinion, and comparative law. The official movie website includes About the Film  with information about the actors, other courtroom dramas, and aspects of the case.

For a strictly historical look at the same case, see NOVA’s Holocaust on Trial (2000). The Companion Website  supplies a transcript, timeline of Nazi abuses, a discussion of Nazi experiments and whether the results of such experiments should be used, and links to other resources.

The following lessons and resources explore Holocaust denial and related issues of libel and freedom of the press.

Lesson plans:

  • Denial on Trial  Students research and present key claims, figures, events, and organizations associated with the notion of “Holocaust revisionism”.
  • Encountering Holocaust Denial  Students analyze arguments of holocaust revisionists and reflect on the motivations behind Holocaust denial.
  • Newsworthy Intentions  Students explore the legal distinction between satire and libel.
  • The Printer’s Trial  The Zenger trial (1735) helped establish truth as a defense against charges of libel and the right of the people to criticize government in print. This NEA resource provides information on the Zenger trial, libel, and the First Amendment.

Internet Resources:


  • History on Trial: My Day in Court with a Holocaust Denier by Deborah Lipstadt
  • Lying About Hitler: History, Holocaust, And The David Irving Trial by Richard J. Evans
  • Denying History: Who Says The Holocaust Never Happened And Why They Say It? By Michael Shermer & Alex Grobman


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