Summary of Time Inc. v. Hill
Citation: 385 U.S. 374
Relevant Facts: In 1952, James Hill, his wife and their five children were taken hostage in their home in Pennsylvania. The family was released after their 19 hour ordeal, unharmed. The suspects were later arrested in a clash with police, and from that clash, two of the suspects were killed. The following year, Joseph Hays published a novel about the Hill hostage crisis. The novel was turned into a play, and then a Life Magazine article was later printed that discussed the myriad inconsistencies regarding the Hills’ experiences during the ordeal. Hill argued that Life Magazine deliberately misrepresented his written story, and as a result, Hill sought damages from Life. Hill received an adverse ruling, and a new trial was ordered. Subsequent to an unsuccessful New York Court of Appeals’ decision, the matter was taken up by the Supreme Court after having granted certiorari to Time Inc.
Issues: The legal question presented was whether a publication that presents misrepresentations about the subject of its coverage is still protected under the First Amendment’s guarantees of free speech, or can it be held liable?
Holding: The Court reversed the lower court decision and found in favor of Time Inc.
Reasoning: The Court found that the lower court erred by not instructing the jury that Time’s liability could only be found if there was proof that it had acted in a knowing and reckless manner to publish false statements about the Hill family. If there was no finding of the publisher’s malicious intent – which there wasn’t – the publisher was in fact protected by the First Amendment. The Court subsequently remanded the matter for a retrial with appropriate jury instruction.
Dissent: Justices Fortas, Clark, and Chief Justice Warren dissented, and asserted that, since Hill was a private rather than public official he lacked the funds and viewership necessary to put forth a vigorous defense against the claims made against him.