St. Amant v. Thompson

Brief Fact Summary.

Defendant made a televised political speech in which he falsely accused plaintiff of criminal conduct. Plaintiff brought suit against defendant for defamation.

Synopsis of Rule of Law.

A showing of reckless disregard requires sufficient evidence that the defendant entertained serious doubts as to the truth of the statement.

Facts.

St. Amant (defendant) made a televised political speech. In his speech, St. Amant falsely accused Thompson (plaintiff), a deputy sheriff, of criminal conduct. Thompson successfully brought a defamation suit against St. Amant in a Louisiana trial court. After trial, the New York Times v. Sullivan case was decided, initiating a set of appeals to determine whether St. Amant’s false statements were made with actual malice.

Issue.

Whether plaintiff satisfied his burden for a showing of reckless disregard to demonstrate actual malice?

Held.

No. Thompson had the burden of proving that St. Amant made the statements with actual malice. Thompson, however, did not satisfy his burden of proof. The judgment is reversed and the case is remanded for further proceedings.

Discussion.

A defamation suit brought by a public official requires a showing that the statement in question was made with actual malice. To prove actual malice, a statement must have either been with knowledge that it was false or with reckless disregard for truth or falsity. Here, the Louisiana Supreme Court erred by misapplying this standard. The state supreme court held that St. Amant had satisfied the actual malice standard although he was not aware that the statements could be false. St. Amant had no knowledge of Thompson’s activities and instead relied solely on a third-party’s affidavit. These facts fall short of demonstrating reckless disregard to prove actual malice.