New York Times Co. v. Sullivan

Citation. 376 U.S. 254, 84 S.Ct. 710, 11 L.Ed.2d

Brief Fact Summary.

Plaintiff filed suit for libel and won. Defendant appealed, arguing its freedoms of speech and press under the First Amendment were violated.

Synopsis of Rule of Law.

Criticism of public officials is protected under the freedom of the press guaranteed by the First and 14th Amendments and is only limited if the injurious statements are both false and made with actual malice.

Facts.

Defendant published an advertisement entitled “Heed Their Rising Voices” which was an appeal for funds to support a student movement, the right to vote, and legal defense of Dr. Martin Luther King, Jr. It did not mention the Plaintiff by name, but did mention his position. Plaintiff filed a libel suit, but did not declare any pecuniary losses.

Issue.

Whether the Alabama libel law as applied to an action brought by a public official criticizing his official conduct in print violates the First and 14th Amendments.

Held.

Yes. The Alabama libel law as applied to an action brought by a public official criticizing his official conduct in print violates the First and 14th Amendments.

Concurrence.

Justice Black

Malice, as defined by the Court is an elusive, abstract concept, hard to prove and hard to disprove. I vote to reverse on the exclusive grounds that the Defendant had the absolute, unconditional right to publish the advertisement.

Justice Goldberg

The First and the 14th Amendments afford to the citizen and to the press an absolute, unconditional privilege to criticize official conduct.

Discussion.

The Alabama law fails to provide the safeguards for freedom of speech and of the press that are required by the First and 14th Amendments. The constitutional guarantees require a public official to additionally show actual malice, or knowledge that the statement was false or was made with reckless disregard of whether it was false or not. Applied here, the evidence is constitutionally insufficient to show the recklessness that is required for a finding of actual malice.  Judgement reversed and remanded.