New York Times Co. v. Sullivan Case Brief

Summary of New York Times Co. v. Sullivan, 376 U.S. 254; 84 S. Ct. 710; 11 L. Ed. 2d 686, U.S. Supreme Court [1964]

Facts: On March 29, 1960, the New York Times carried a full-page advertisement entitled, “Heed Their Rising Voices," which contained several paragraphs describing unfair treatment of Alabama State College student protestors, two of which specifically mentioned unfair treatment by the police. Respondent L.B. Sullivan was one of three commissioners of the city of Montgomery, Alabama. One of his main duties was the supervision of the city police department. Although none of the statements made within the advertisement directly named Sullivan, he argued that, as supervisor of the city police department, he was being accused of allowing the described treatment of the students.

It was found that some of the statements contained in the two paragraphs in question were not accurate descriptions of what had actually occurred and placed the police department in a very unfavorable light. Additionally, all witnesses who testified stated that they did not believe the statements in reference to the respondent.

Respondent Sullivan brought a claim of libel against four of the individuals whose names, among others, were in the advertisement and against the New York Times for publishing the advertisement.

History: The trial court found for respondent and awarded him damages of $500,000 against all defendants on the grounds that the statements in the advertisement were libelous per se [legal injury being implied without proof of actual damages], false, and not privileged. On appeal, the Supreme Court of Alabama affirmed the decision. Plaintiffs appealed to the United States Supreme Court.

Issue: Can a public figure receive damages in a civil libel action, if malice is not proven?

Ruling: No. The U.S. Supreme Court reversed the judgment and remanded the case.

Rule/Analysis: The Supreme Court held that petitioner was protected by the First and Fourteenth Amendments. As such, a public official [respondent] was prohibited from recovering damages for a defamatory falsehood relating to his official conduct unless it could be proven that the statement was made with actual malice.

Summary: Respondent presented no evidence to show petitioner was aware of erroneous statements or was reckless in that regard, and therefore could not prove malice. In the absence of malice, respondent could not recover damages.

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