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New York Times Co. v. Sullivan

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Significance: The Supreme Court redefined freedom of the press by requiring that someone wishing to recover damages from a newspaper for a false story had to show that the newspaper had actual malice or a reckless disregard for the truth.


The New York Times printed an advertisement appealing for funds for civil rights organizations that included technically false statements about Montgomery, Alabama, police commissioner Sullivan. The Supreme Court was asked to rule on a half-million dollar civil damage award to the Sullivan. There was no showing that the Times had any actual malice or reckless disregard for the truth in printing the statements. The most that could be alleged was that the Times was negligent. The Court's unanimous decision in favor of the newspaper gave vastly greater protection to the news media from libel suits resulting from the publication of factual errors. In his opinion for the Court, Justice William J. Brennan, Jr., pointed out that allowing the damage award from the Alabama courts would provoke greater fear than criminal prosecution. Sullivan could show no monetary loss, but the newspaper would face a loss one thousand times greater than the maximum fine under Alabama criminal statutes. Because double jeopardy protection does not exist in civil litigation, other awards could be levied against the newspaper for the same advertisement. Fear of successive monetary losses would stifle the press, Brennan argued. The Court prohibited public officials from recovering damages for a defamatory falsehood relating to their official conduct unless they proved that the statement was made with actual malice that is, with knowledge it was false or with a reckless disregard for whether it was false or not. As a result, it became extraordinarily difficult for public officials to ever win a damage suit against a newspaper or television station, no matter how false or defamatory the statements against them were. The same situation also confronts those people who are defined as “public figures.” A public figure, for purposes of defamation law, is a person who “thrusts himself into a public controversy in order to affect its outcome.” An otherwise little-known person unwillingly caught up in a matter of public interest is not a public official and thus need prove only negligence (not actual malice) to prevail against a defamer, according to Wolston v. Reader's Digest Association (1979). “Public figure” is a more vague term than “public official,” and for that reason, the Court has had to deal with a large number of libel suits involving people who believe they are ordinary citizens but whom the newspapers claim are public figures. Generally speaking, a public figure would be a movie star, a sports hero, or some other well-known person who had been mentioned in the press before a controversy arose. Presumably, the laws of libel apply to any ordinary citizen who is libeled or defamed by a newspaper, and private people are able to recover damages from newspapers or magazines.