Citation: 376 U.S. 254 (1964)
Vote of the Court: It was a unanimous decision by all nine justices with two concurrences for the New York Times Company.
Legal Issue(s): Do the First Amendment protections of free speech and freedom of the press include false or libelous statements? To what extent can state courts apply their own rules of law in regards to their interpretation of libel law?
Procedure of the case: The case was first tried in the Montgomery County Circuit Court in Alabama. The jury entered a verdict against the New York Times. The New York Times appealed the decision to the Alabama State Supreme Court who confirmed the judgment and verdict of the trial court. The New York Times filed a petition for writ of certiorari with the United States Supreme Court to review the Alabama Supreme Court’s decision. The Court agreed to hear the case during their spring 1964 term.
Facts: In March 1960, a full-page advertisement entitled, “Heed Their Rising Voices” was carried in the New York Times newspaper seeking support and donations for Martin Luther King, Jr. and the civil rights movement in the southern United States. Some of the statements in the advertisement were inaccurate. When the advertisement was published, L.B. Sullivan worked as the Commissioner of Public Affairs for the city of Montgomery, Alabama. As Commissioner of Public Affairs, Sullivan was responsible for supervision over the Montgomery Police Department. Although the advertisement did not mention him by name, it did mention the police department. Sullivan took offence with advertisement and filed a libel suit against the four clergymen who had signed their names in support of the advertisement and the New York Times Company. Sullivan claimed that several statements in the advertisement about the police had damaged his reputation as Commissioner of Public Affairs by claiming facts that were false. At trial, the New York Times argued that it although it had not made an independent effort to verify the accuracy of the statements, it nevertheless agreed to print the advertisement because it did not have a reason to believe that any of the statements were false or that any of the statements referred to Sullivan personally. The trial jury however, found the statements to be libelous. Sullivan won the suit and was awarded $500,000 in damages by the trial court judge who applied Alabama state libel law in determining the amount of damages.
Question Presented: Can a state court award damages to a public official for statements about his official conduct that were found to contain false or incorrect facts?
Answer: No. A state court may not award damages to a public official who brings a libel suit against another in regards to statements describing his official duties unless the can show that the statements were made with actual malice which is to say that the statements were made either with: (1) the knowledge that they were false or (2) reckless disregard of whether it was true or false. Since Sullivan did not prove that the statements in the advertisement were made with actual malice, he was not entitled to the damages award and therefore the decision by the Alabama Supreme Court was reversed and the case was sent back or remanded to the Montgomery County Circuit Court to be retried with instructions to apply the new standard as set forth in the Court’s opinion.
Court’s reasoning: Under the Court’s analysis, the First Amendment’s protections of free speech gave citizens the right to criticize their government and debate important public issues in an “uninhibited, robust and wide-open” manner even if that criticism and debate includes “unpleasantly sharp attacks on government and public officials.” The Court also found that although it “was inevitable” that such free and open debate would contain some inaccuracies and mistakes but nevertheless the freedom to makes those statements must still be protected. Therefore, in order for a public or government official to win a libel suit, the First Amendment required that he prove that the statements were false and that the person making the statements did so with actual malice rather than simply making them in the heat of free and open debate. The Court further found that the First Amendment protection had priority over state libel laws to the contrary and from now on, state libel laws would also have to conform to the absolute malice standard.
Concurrence: Justice Black in his concurrence, while agreeing with the majority opinion reversing the award of damages to Sullivan and that the Constitution “delimits’ states from applying their own libel laws, Justice Black’s felt that the majority did not go far enough in controlling state actions or protecting the freedom of speech. According to Justice Black’s theory, there was no need to show actual malice before an award of damages could be made. Instead, the Constitution placed an absolutely bar against public officials suing anyone for making statements about his official conduct. Under Justice Black’s analysis, the purpose of the First Amendments’ right to free speech was to allow people to be able to “critically discuss public affairs” without fear of retribution but the inclusion of an absolute malice standards was not protective enough of the right and in some cases could lead to confusion about the absolute right to free speech embodied in the First Amendment.
Significance of the case: The case was significant for two reasons. First, the Court expanded the First Amendment’s protection of free speech to cover libelous statements by limiting the situations in which a public official could recover damages for libel from publications. Prior to the decision a public official, like Sullivan simply needed to claim statements were harmful to their reputation without actual proof of damages. However, after the decision, as long as there is an absence of malice, public officials are barred from recovering damages for the publication of false statements about their official conduct. Proving absolute malice while not impossible is much more difficult and therefore has made public officials less likely to file a suit unless they have proof of malice. Secondly, in finding that a state court’s application of libel law must conform to the Constitution through the First and Fourteenth Amendments, the Court in essence “federalized” law had previously been under the strict control of state courts. Under the Court’s holding, publications across the nation were now able to escape being subject to state libel laws that might be used “to punish or harass critics” by making all libel laws subject to the protections of the higher and more uniform Constitutional standard for libel.
New York Times v. Sullivan. (n.d.) Retrieved February 16, 2014, from http://www.oyez.org/cases/1960-1969/1963/1963_39
New York Times v. Sullivan. (n.d.) Retrieved February 16, 2014, from http://www.law.cornell.edu/supremecourt/text/376/254
New York Times v. Sullivan Podcast. (n.d.) Retrieved February 15, 204, from http://www.uscourts.gov/multimedia/podcasts/Landmarks/NewYorkTimesvSullivan.aspx
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Citation: 376 U.S. 254 (1964)
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