Brief Fact Summary. The Plaintiffs, Butts and Walker (Plaintiffs), were public figures and not public officials. Both were awarded damages for defamation. The Defendant, Curtis Publishing Co. (Defendant), appealed to extend the constitutional safeguards outlined in New York Times to public figures.
Synopsis of Rule of Law. A public figure has the same standard of proof for libel as a public official does under New York Times.
Held. Yes. Judgments affirmed.
* Justice John Harlan (J. Harlan) argued that the actions cannot be analogized to prosecutions for seditious libel. Neither of the Plaintiffs has any position in government, which would permit a recovery by him to be viewed as a vindication of governmental policy. Neither of the Plaintiffs was entitled to a special privilege protecting his utterances against accountability in libel.
* “Speech can rebut speech, propaganda will answer propaganda, [and] free debate of ideas will result in the wisest governmental policies.”
* Both Plaintiffs commanded a substantial amount of independent public interest at the times of the publications. Both had sufficient public interest and sufficient access to the means of counterargument to be able to expose though discussion the falsehood and fallacies of the defamatory statements.
* Libel actions of the present type cannot be left entirely to state libel laws. Both the Plaintiffs commanded a substantial amount of independent public interest at the time of the publications. The Supreme Court holds that a public figure is subject to the same standards for recovery from libel as a public official. Looking at the evidence in the cases, the Supreme Court finds that Plaintiff No. 1 has meet the standard set forth in New York Times and Plaintiff No. 2 has not.
Dissent. Justice Hugo Black (J. Black) argued that it is time for the Supreme Court to abandon New York Times Co. v. Sullivan and adopt the rule to the effect that the First Amendment of the United States Constitution (Constitution) was intended to leave the press free from the harassment of libel judgments.
Concurrence. Chief Justice Earl Warren (J. Warren) stated that the differentiation between public figures and public officials has no basis in law, logic, or the First Amendment of the Constitution. Public figures like public officials play an influential role in ordering society. Plaintiff No. 2’s should be reversed, as there was only evidence of negligence. As for Plaintiff No. 1’s case J. Warren was satisfied that the evidence discloses the reckless disregard for the truth.
* Justice William Brennan (J. Brennan) argues that the evidence unmistakably would support a judgment for Plaintiff No. 1 under the New York Times standard.
Discussion. Public figures have just as much influence and access to the public as do public officials. In this case, the majority would rather have the Plaintiffs, who are public figures, use newspapers, TV shows, public appearances and the like to battle defamatory statements made without malice. In the decision in this case, the Supreme Court takes a hands-off approach in dealing with defamatory statements that were made by mistake.