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Hustler Magazine v. Falwell

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Significance: The Supreme Court ruled against a religious leader's libel claim, providing a right of parody for the press.


Publisher Larry Flynt's Hustler magazine printed an issue containing a parody of Jerry Falwell, in which the conservative religious leader was depicted having sex with his mother in an outhouse. A Virginia federal district court jury rejected Falwell's libel claim because it believed that no reasonable person would believe the parody was truthful but awarded Falwell $200,000 for “intentional infliction of emotional distress” a ruling that did not require that a false statement was made. By an 8-0 vote, the Supreme Court overturned the lower court's decision. In the opinion for the Court, Chief Justice William H. Rehnquist wrote that a public figure could not recover for intentional infliction of emotional harm absent a libelous statement made with actual malice. Public figures such as Falwell must expect robust criticism because the press protection under the First Amendment takes precedence over their emotional loss from nonlibelous statements.