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Libel and the Holocaust

April 18, 2021

Gdansk railway station and Warsaw Ghetto burning (May 1943), Author Unknown (PD)

An obscure Polish libel case may have a chilling effect on research regarding the Holocaust worldwide [1][2].


Nazi genocide took the lives of 3 million Polish Jews during the Holocaust [3].  No doubt exists about this.

At least 90% of Poland’s Jews were exterminated.  Hundreds of synagogues were destroyed [4].  No less than 457 concentration and death camps were located in German-occupied Poland during WWII [5].  These included the infamous Auschwitz, Birkenau, Sobibor, and Treblinka [6]. 

National Responsibility Denied

Despite this, Poland has remained adamant that the nation did not participate in persecution of the Jews [7].  In 2018, an Amendment to the Act on the Institute of National Remembrance criminalized any public statements attributing collective responsibility to the Polish nation for crimes related to the Holocaust.

Pogroms and Complicity

Statutory religious tolerance notwithstanding, antisemitism in Poland long pre-dated the Holocaust [8].  Pogroms were not uncommon.

While individual Poles did risk their lives to hide and aid Jews during WWII, others were complicit in – or apathetic to – the fate of the Jews.  In multiple instances, the same person both saved and denounced Jews.

Alleged Libel

Which brings us to the case of Leszczynska v. Engelking.

Historians Barbara Engelking and Jan Grabowski only briefly mention the deceased Edward Malinowski in their 1600 page tome titled “Night Without End:  The Fate of Jews in Selected Counties of Occupied Poland.”  Malinowski, a village elder and uncle of the 81 y.o. plaintiff, Filomena Leszczynska, is alleged both to have robbed and saved Estera Siemiatycka by finding her work as a forced laborer.

Siemiatycka, also now herself deceased, actually testified on Malinowski’s behalf in a 1950 Communist trial which acquitted him of collaboration with Poland’s Nazi occupiers.  However, Siemiatycka later recanted her testimony in an interview with the Shoah Foundation, accusing Malinowski of having been an accomplice to the deaths of several dozen Jews turned over to the Germans after hiding in the woods.

The historians relied in their book on the Shoah interview.  Leszczynska and her backers at the Polish Anti-Defamation League (RDI) claim the book defames a Polish hero and the honor of the Polish nation.

The scholars fear this libel case is an effort to discredit their work, and discourage researchers from investigating the truth of Polish collaboration in the mass murder of Jews.

In the United States, one cannot libel the dead.  However, the District Court of Warsaw has directed these historians to issue a written apology to Leszczynska for “providing inaccurate information” regarding her uncle.

[1]  ABC News, “Holocaust research could hinge on Polish libel case” by Guy Davies and Dragana Jovanovic, 2/7/21,

[2]  ABC News, “Holocaust scholars ordered to apologize in Polish libel case” by Vanessa Gera and Monica Scislowska, 2/9/21,

[3]  Wikipedia, “The Holocaust in Poland”,

[4]  Handshouse Studio, “A Brief History of Polish Wooden Synagogues”, 2014-2020,

[5]  Wikipedia, “German camps in occupied Poland during WWII”,

[6]  Encyclopedia Brittanica, “Extermination Camp”,

[7]  Wikipedia, “Polish death camp controversy”,

[8]  Wikipedia, “History of Jews in Poland”,


  1. This story is both troubling as well as odd but one thing I gleaned during a trip to Berlin several years back is just how much the German people and government try to distance themselves from that painful past.

    They do not want any association to a nation, their nation, that was capable of such atrocities— it’s as if they want to pretend it never happened.

    I wonder what is behind this Polish push to bury its compliance…

  2. By the grace of God some Jewish survivors were able to hide among society.
    I can not imagine the stress they went through, insuring their identity was not exposed.
    Too many try to rewrite history, but the truth remains, and is uncovered.

  3. Deny if they wish. The evidence, however, says otherwise. To deny their complicity in the Holocaust is both foolish and indicative of the day in which we live where accountability is fast becoming a thing of the past. The Polish government would be wise to rethink their strategy and acknowledge the obvious. At least those still surviving the unthinkable horrors they were subjected to could take some minuscule solace from that.

    One thing is certain, and that is the Almighty will one day demand an answer.

  4. For what it’s worth… While in New Zealand with our expat children a year ago, I recall reading two books on this subject, and one in particular went into detail about life in Poland in WW2, sadly confirming SOME Poles’ co-operation with the Nazis of the day. What did Jeremiah say about the ‘heart of man…?’ ‘The heart is devious above all else; it is perverse – who can understand it?‘ (17:9/NRSV) Apart from Christ, we are ALL capable of the most terrible things!

    • Human behavior is complex. I am sure that fear, self-preservation, rationalization, ambition, and antisemitism all to varying degrees played a role in the decisions individuals made to cooperate w/ the Nazis. None of us know for certain what we might do in similar circumstances which is exactly why truthful research into the past is so important. It is far too easy to whitewash our actions.

  5. Während unseres Geschichtsunterrichts in der Schule wurde die Nazi-Zeit und die Verbrechen an den Juden verschwiegen. Jahre später war ich in Israel und habe dort längere Zeit bei einer jüdischen Familie gelebt, obwohl ich Deutsche war und einige der Verwandten in Konzentrationslagern verloren hatten. Sie haben mir so viel erzählt, ohne Bitterkeit,und waren extrem freundlich zu mir. Seitdem sehe ich vieles anders, und ich bin froh über die Erfahrungen.
    Danke liebe Anna für Deine sorgfältigen Recherchen und Berichte. Liebe Grüße Marie

  6. Reblogged this on Senioren um die Welt and commented:

    Anna Waldherr, eine sehr engagierte Rechtsanwältin für die Armen in den USA, schreibt folgenden Beitrag:

  7. Don’t know why some humans feel the need to be cruel

  8. My thanks for the reblog, Tonya.

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  1. Libel and the Holocaust – Tonya LaLonde

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