Cantrell v. Forest City Publishing Co

Citation. Cantrell v. Forest City Pub. Co., 419 U.S. 245, 95 S. Ct. 465, 42 L. Ed. 2d 419, 1 Media L. Rep. 1815 (U.S. Dec. 18, 1974)

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CitationCantrell v. Forest City Pub. Co., 419 U.S. 245, 95 S. Ct. 465, 42 L. Ed. 2d 419, 1974 U.S. LEXIS 158, 1 Media L. Rep. 1815 (U.S. Dec. 18, 1974)

Brief Fact Summary. Mrs. Cantrell and her children (Plaintiffs) brought suit against Forest City Publishing Co. (Defendant), when its publication, The Plain Dealer, published a feature story stressing Plaintiffs’ poverty.

Synopsis of Rule of Law. The First Amendment does not preclude a plaintiff from recovering against a media defendant who uses falsehoods in reporting on a matter of public concern.

Points of Law - Legal Principles in this Case for Law Students.

The constitutional protections for speech and press preclude the application of the New York statute to redress false reports of matters of public interest in the absence of proof that the defendant published the report with knowledge of its falsity or in reckless disregard of the truth.

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Facts. In 1967, Mrs. Cantrell’s husband was killed during a collapse of a bridge. The Plain Dealer covered the story, focusing on the death of Mr. Cantrell and its impact on his family. Several months thereafter, the Plain Dealer returned to write a follow-up on the family. They went to Plaintiffs’ residence, spoke with the children, and took pictures. Mrs. Cantrell was not home when the reporters appeared. Later, an article was published, stressing the family’s poverty and the impact of the bridge disaster. The article also alluded to Mrs. Cantrell’s presence and attributed characteristics to her expression that did not take place. Mrs. Cantrell and her children brought suit, claiming they had been depicted in a false light, under the theory of invasion of privacy. After trial, the district court denied Plaintiffs’ demand for punitive damages, but allowed some damages for Mrs. Cantrell. The court of appeals found that the district court should not have allowed recovery, and reversed
maintaining that verdict should have been directed. The Supreme Court of the United States granted certiorari.

Issue. Whether the court of appeals acted appropriately when it set aside a jury verdict on an invasion of privacy claim, when the Defendant was a media publisher?

Held. Reversed.
* The Supreme Court held that the paper did publish falsehoods, and as such, was liable for the actions of its reporters, for damages sustained by the Plaintiffs.

Discussion. While reporters can claim First Amendment privilege when they report on issues of public concern, they may not hide behind this privilege when their stories knowingly represent Plaintiffs in a false light.

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