St. Amant v. Thompson

Brief Fact Summary.

During a televised speech, the Defendant, St. Amant (Defendant), quoted material from a third person that falsely accused the Plaintiff, Thompson (Plaintiff), of criminal activities. The trial court found in favor of the Plaintiff. The appellate court reversed. The Louisiana Supreme Court affirmed the trial court’s decision.

Synopsis of Rule of Law.

In order to prove reckless disregard for the truth, there must be sufficient evidence to show that the defendant entertained serious doubts as to the truth of his publication.

Facts.

The Defendant made a televised political speech during which he read questions and answers he had previously asked a union member. The answers falsely charged the Plaintiff, a deputy sheriff, with criminal conduct. The trial judge awarded damages for defamation. The intermediate appellate court reversed, finding that the Defendant had not acted with actual malice. The Louisiana Supreme Court reversed, finding sufficient evidence that the Defendant acted with reckless disregard for the truth. The United States Supreme Court (Supreme Court) granted certiorari.

Issue.

Was the Supreme Court of Louisiana correct in its determination that defendant acted with reckless disregard for the truth?

Held.

No. Judgment reversed and remanded.
* The Supreme Court accepts the Louisiana courts determinations that the material published was false and that the Plaintiff was a public official for the purpose of this case. Therefore, the actual malice standard is applicable. It is clear that the Defendant had no personal knowledge of the Plaintiff’s activities, but rather relied only on the union member’s affidavit. He failed to verify the information, mistakenly believing that he had no responsibility for the broadcast because he was quoting someone else’s words.
* In order to meet the actual malice standard, the Defendant must have a high degree of awareness of the statements probable falsity. This standard is not measured by whether a reasonably prudent man would have published the material or would have investigated before publishing. Rather, there must be sufficient evidence to show that the Defendant entertained serious doubts as to the truth of his publication.
* A defendant cannot insure a favorable verdict by simply stating that he published with a belief that the statement was true. The jury must instead determine if the publication was made in good faith. However, in this case the evidence against the Defendant was insufficient to meet the reckless disregard requirement for actual malice.

Dissent.

Justice Abe Fortas (J. Fortas) argued that the Defendant has a duty to check the reliability of a statement.
Concurrence. Justices Hugo Black (J. Black) and Justice William Douglas (J. Douglass) stated there should be an absolute privilege in defamation cases involving public figures.

Discussion.

In support of its decision, the Supreme Court points out that it is essential to protect some erroneous publications in order to ensure that the First Amendment of the Constitution is upheld.