New York Times v. Sullivan (1964)
Sunday, December 27, 2009 at 3:01PM Read the opinion here.
Issue. To what extent does constitutional protections of freedom of speech and the press limit a State's power to limit damages in a libel action brought by a public official for criticism of his official conduct?
Background. The New York Times ran an ad by the Committee to Defend Martin Luther King and the Struggle for Freedom in the South. The ad claimed there was an unprecedented wave of terror against blacks engaged in non-violent demonstrations in the South. Sullivan, the Montgomery, Alabama police commissioner, objected to claims in the ad that he believed to be false and he sued for libel. Even though Sullivan offered no proof that he suffered any pecuniary damages, he was still awarded $500,000 under Alabama's libel law.
The Supreme Court overruled the judgment because Alabama's libel law did not provide sufficient safeguards for freedom of speech and of the press when a libel action is brought by a public official against critics of his official conduct.
Court's Analysis. The Court recognized the profound national commitment to the principle that debate on public issues should be uninhibited, robust and wide open. At times, the public debate may become caustic and unpleasant when it comes to attacks on the government and public officials.
Sometimes, the debate may even lead to misstatements and falsehoods. Under Alabama's libel law, such falsehoods, even made mistakenly or negligently, could cost an individual or a newspaper $500,000 even if the "victim" has not suffered any loss (harm to reputation is assumed).
Such a civil law would have a chilling effect on speech and press criticism of the government and public officials. Therefore, for a public official to recover damages for a defamatory falsehood relating to his official conduct, he must prove that the statement was made with "actual malice", or the individual knowingly made a false statement or recklessly disregarding whether the statement made was true.
In this case, the New York Times was no more than negligent in failing to discover the misstatements in the ad and the proof was constitutionally insufficient to find actual malice. Further, the ad did not even reference Sullivan by name.
The Court will not allow good-faith critics of the government to be penalized for their criticism through libel laws. It runs counter to the First Amendment freedoms of speech and press.