New York Times V. Sullivan 376 U.S. 254 (1964) – Law Essay (400 Level Course)
Facts: The New York Times ran a full – page fund raising advertisement for the civil rights movement called ”Heed Their Rising Voices” on March 29, 1960. The Article was about the unfair treatment of Alabama State college student protestors. There were several minor errors of fact against the police department.
L.B. Sullivan, the Montgomery city commissioner, filed a libel suit against the newspaper and the four African American ministers who were listed as endorsers of the ad, claiming that that the allegations against the Montgomery police defamed him personally.
Even though the ad never stated his name or accused him personally, Sullivan felt that it implied him because he was the city official in charge of the police department. Under Alabama law, Sullivan did not have to prove that he had been harmed: and a defense claiming that the ad was truthful was unavailable since the ad contained factual errors. Sullivan then was awarded a $500,000 judgment.
Judicial History:
The trial court awarded Sullivan $500,000 in his favor. The court of appeals affirmed the decision. The United Supreme Court ruled that case be reversed and remanded.
Issues:
Whether a public official can receive damages in a civil libel action suit if malice is not proven?
Rules:
No. The United State Supreme Court reversed the judgment and remanded the case.
Analysis / Conclusion:
A state cannot, under the First and Fourteenth Amendment, award damages to a public official for defamatory falsehood relating to his official conduct unless he proves “actual malice” that the statement was made with knowledge of its falsity or with reckless disregard of whether it was true or false.