Citation. 376 U.S. 967 84 S. Ct. 1130 12 L. Ed. 2d 83 1964 U.S.
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The Petitioner, the New York Times (Petitioner), printed an advertisement that included false statements relating to the Respondent, L.B. Sullivan, an elected official’s (Respondent) conduct. The Respondent brought suit for defamation and the trial court found in his favor.
Synopsis of Rule of Law.
The First Amendment of the United States Constitution (Constitution) requires proof of actual malice for libel actions brought by public officials against critics of their official conduct.
Facts.
The Respondent was one of three elected Commissioners of Montgomery, Alabama. His duties included supervision of the police department. The Respondent brought suit against the Petitioner, alleging that he was libeled by statements made in a full-page advertisement carried by the Petitioner. The advertisement included allegations that armed police in Montgomery surrounded the State Capitol when students gathered there to protest and that Dr. Martin Luther King has repeatedly been harassed by police in the south. The Plaintiff was not mentioned by name, but claimed that the statements attributed misconduct to him as supervisor of the Montgomery Police Department. A jury at Circuit Court awarded respondent damages of $500,000 and the Supreme Court of Alabama affirmed.
Issue.
Are States limited in their power to award damages in a libel action brought by a public official against critics of his official conduct?
Held.
Yes. Judgment reversed and remanded.
* It is clear from the facts that some of the statements made in the advertisement were not accurate. However, an important purpose behind the First Amendment of the Constitution is to allow for uninhibited debate of public issues. It has been established that States or the federal government may not hinder debate of public issues through criminal statutes. This First Amendment constitutional protection is also applicable to civil libel actions. Safeguards are particularly important in this area because of the lack of indictment requirements and the lower burden of proof in civil cases.
* Because of these constitutional concerns, the Supreme Court of the United States (Supreme Court) holds that a public official may not recover for defamatory falsehood relating to his official conduct unless he proves the statement was made with actual malice. Actual malice is defined as knowledge that the statement was false or acting with reckless disregard as to whether it was false or not. This privilege includes matters of public concern, public men, and candidates for office.
* In the present case, there is no evidence that the statement printed by the Petitioner indicated malice at the time of publication. Further, the Petitioner’s failure to retract the statement in this case is not adequate evidence of malice for constitutional purposes.
Concurrence. Omitted.
Discussion.
The majority of courts that have considered the implications of this case have determined that the privilege is limited to expressions of opinion and does not include misstatements of fact.
