Case Study of: New York Times Co. v. Sullivan, 376 U.S. 254 (1964)

Facts:

The parties involved were New York Times Company versus Sullivan.

A Civil Rights organization bought a full-page ad space form the New York Times, which was titled “Heed Their Rising Voices.” The ad was meant to garner contributing donations to defend Martin Luther King, Jr. on perjury charges. The ad had gotten the attention of the Montgomery, Alabama police because of allegations to them, made in the ad, that were false or exaggerated. L.B. Sullivan, The city Public Safety Commissioner, felt that the comments made to the Montgomery, Alabama police were criticisms of him and that it was ruining his reputation. Sullivan was the Commissioner of the Police Department, Fire Department, Department of the Cemetery, and Department of Scales for Montgomery, Alabama. Sullivan felt this way even though he was never mentioned in the ad. The New York Times soon recovered a written request sent from Sullivan requesting them to publicly retract the information, as required for a public figure to seek punitive damages in a libel action under Alabama law.

The New York Times was puzzled by the request, and so they refused it. Soon after, Sullivan filed libel action against the New York Times and a group of African-American ministers mentioned in the ad. A Montgomery Trial judge determined that the advertisement was libelous per se, meaning Sullivan doesn’t have to show evidence that his reputation is being hurt or damaged. The judge awarded Sullivan $500,000 in damages. The Alabama Supreme Court affirmed the Trial Courts’ judgment, and then the New York Times appealed.

Issue:

The question laid upon the court: does the First Amendment allow a public official to bring a defamation action for false statements about public issues?

Rule of Law:

The rule of law in claims of defamation or libel states that the First Amendment requires “actual malice,” meaning that it requires that the plaintiff show that the defendant knew the statements were false or acted with gross recklessness, with intent, when publishing something.

The majority opinion is that when a statement concerns a public figure, it is not enough to show that it is false for the press to be liable for libel and that not only does malice need to be proven, but that “actual malice” needs to be proven as well. This allows for debate on public issues and raises the burden of proof required for plaintiffs in libel claims when going against newspapers and other media outlets. In a concurrence opinion, Justice Blake wrote that he felt the standard of actual malice did not go far enough in providing First Amendment protections as it wasn’t clear enough to be consistently applied.

It was a unanimous majority decision for New York Times Company.

Key Quote and Precedent:

“To persuade others to his own point of view, the pleader, as we know, at times resorts to exaggeration, to vilification of men who have been, or are, prominent in church or state, and even to false statement. But the people of this nation have ordained, in the light of history, that, in spite of the probability of excesses and abuses, these liberties are, in the long view, essential to enlightened opinion and right conduct on the part of the citizens of a democracy,” Cantwell v. Connecticut,310 U. S. 296, 310 U. S. 310, Justice Brennan wrote in the opinion.

 My Opinion:

I do not think the New York Times Co. v. Sullivan is unfair to public figures because it allows us to talk about things of public concern. If the press could easily be libeled, that could create a chilling effect on media, and nobody would want to talk about anything unless they want to go to court.

I don’t think this ruling could be changed because with all the news going around, the way technology is, and how great the backlash, or support, for President Trump, currently stands, it would be tough to accomplish that goal of changing the law. Also, there are way too many precedents for ignoring or merely throwing away to enact this law change. In my opinion: If you are a public figure, people are going to talk about you in either a good or bad way, and handling that is just one role of the job.

Citations:

https://www.oyez.org/cases/1963/39

https://supreme.justia.com/cases/federal/us/376/254/#tab-opinion-1944786


A 1st Amendment assessment from my COMS 400 Communication Law and Ethics class at Radford University. This is 5 of 10.

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