New York Times Co. v. Sullivan

The New York Times Co. v. Sullivan
Supreme Court of the United States
Argued January 6, 1964 Decided March 9, 1964
Full case name	The New York Times Company v. L. B. Sullivan
Citations	376 U.S. 254 (more) 84 S. Ct. 710; 11 L. Ed. 2d 686; 1964 U.S. LEXIS 1655; 95 A.L.R.2d 1412; 1 Media L. Rep. 1527
Case history
Prior	Judgment for plaintiff, Circuit Court, Montgomery County, Alabama; motion for new trial denied, Circuit Court, Montgomery County; affirmed, 144 So. 2d 25 (Ala. 1962); cert. granted, 371 U.S. 946 (1963).
Holding
A newspaper cannot be held liable for making false defamatory statements about the official conduct of a public official unless the statements were made with actual malice.
Court membership
Chief Justice Earl Warren Associate Justices Hugo Black · William O. Douglas Tom C. Clark · John M. Harlan II William J. Brennan Jr. · Potter Stewart Byron White · Arthur Goldberg
Case opinions
Majority	Brennan, joined by Warren, Clark, Harlan, Stewart, White
Concurrence	Black, joined by Douglas
Concurrence	Goldberg (in result), joined by Douglas
Laws applied
U.S. Const. amends. I, XIV

New York Times Co. v. Sullivan, 376 U.S. 254 (1964), was a landmark U.S. Supreme Court decision ruling that the freedom of speech protections in the First Amendment to the U.S. Constitution restrict the ability of public officials to sue for defamation.^[1][2] The decision held that if a plaintiff in a defamation lawsuit is a public official or candidate for public office, then not only must they prove the normal elements of defamation—publication of a false defamatory statement to a third party—they must also prove that the statement was made with "actual malice", meaning the defendant either knew the statement was false or recklessly disregarded whether it might be false.^[2] New York Times Co. v. Sullivan is frequently ranked as one of the greatest Supreme Court decisions of the modern era.^[3]

The underlying case began in 1960, when The New York Times published a full-page advertisement by supporters of Martin Luther King Jr. that criticized the police in Montgomery, Alabama, for their treatment of civil rights movement protesters.^[2] The ad had several inaccuracies regarding facts such as the number of times King had been arrested during the protests, what song the protesters had sung, and whether students had been expelled for participating.^[2] Based on the inaccuracies, Montgomery police commissioner L. B. Sullivan sued the Times for defamation in the local Alabama county court.^[2] After the judge ruled that the advertisement's inaccuracies were defamatory per se, the jury returned a verdict in favor of Sullivan and awarded him $500,000 in damages.^[2] The Times appealed first to the Supreme Court of Alabama, which affirmed the verdict, and then to the U.S. Supreme Court, which agreed to hear the case.

In March 1964, the Court issued a 9–0 decision holding that the Alabama court's verdict violated the First Amendment.^[1] The decision defended free reporting of the civil rights movement campaigns in the southern United States. It is one of the key decisions supporting the freedom of the press. The Court reasoned that defending the principle of wide-open debate will inevitably include "vehement, caustic, and...unpleasantly sharp attacks on government and public officials." Before this decision, there were nearly $300 million in libel actions from the southern states outstanding against news organizations, part of a collective effort by southern officials to use defamation suits to prevent critical coverage of civil-rights issues in out-of-state publications.^[4][5] The Supreme Court's decision, and its adoption of the actual malice standard, reduced the financial exposure from potential defamation claims and frustrated efforts by public officials to use these claims to suppress political criticism.^[4][5] The Supreme Court has since extended Sullivan's higher legal standard for defamation to all "public figures". This has made it extremely difficult for a public figure to win a defamation lawsuit in the United States.