Summary of Associated Press v. Walker
Citation: 389 U.S. 28
Relevant Facts: Edwin Walker sued the Associated Press (AP), claiming that it had erroneously reported that Walker had “led a charge of students against federal marshals” during a riot following the enrollment of the first black student at the University of Mississippi. The story was proven to be false, but the trial judge’s verdict was overturned once the AP appealed the decision. Although the Court found that the story was inaccurate, it also found that no actual malice existed. Walker had a reputation for incitement and provocation in politics. Since the story was pursued in an even and investigatory tone and led by a credible reporter, no malice was found. The matter was appealed.
Issues: The legal question presented was whether based on the USSC’s NYT v. Sullivan ruling, the allegations made against Walker as well as Butts (another petitioner) were libelous.
Holding: The Court held that no libel had occurred.
Reasoning: The Court reasoned that the story, while factually incorrect, was not malicious and did not rise to the level of an important event that would have done irreparable harm to Walker’s reputation. Consequently, the Court ruled that Walker was not the victim of a malicious action, i.e. reporting, thus denying his claims for damages.
Conclusion: Although Walker was a public figure, he was not a public official. And as a result, the Supreme Court found that in lieu of being able to prove malice, Walker and those like him (public figures) do not automatically have a legitimate claim to damages if malice cannot be proven.