New York Times v. Sullivan

New York Times v. Sullivan

Presented by James M M Baldwin

Case Facts

Civil Rights movement

1964

New York Times ad

defends Martin Luther King, Jr.

on perjury charges

several

minor

factual

inaccuracies

Public Safety Commissioner

L.B. Sullivan said

criticism of subordinates

reflected on him

he was not mentioned

Sullivan sent written request

to the Times

to publicly retract

as required for public figures

to seek punitive damages

in libel law.

Times refused

claimed puzzled by request

Sullivan filed libel

against Times

and

African American ministers

Who funded ad

jury awarded $500,000

damages

state supreme court affirmed

Times appealed

 

Question

Did libel law

Unconstitutionally infringe

First Amendment’s

Freedom of speech of press protections?

 

Conclusions

To sustain a claim

of defamation

or libel,

First Amendment requires

plaintiff shows

defendant knew

statement was false

or reckless

without investigating

it was accurate.

In unanimous opinion

the Court ruled

for the Times.

When statement concerns

public figure

it’s not enough

to show it’s false

for press to be

liable for libel.

Instead, 

knowledge of

or reckless disregard for

its falsity.

"actual malice"

not meaning

malicious purpose.

In libel law,

“malice” meant knowledge

or gross recklessness

rather than intent,

courts found it difficult

to imagine

someone would

knowingly

disseminate

false information

without bad intent.