Anderson v. Liberty Lobby, Inc.
91 L. Ed. 2d 202 · Supreme Court of the United States · 1986
Facts
Respondent Liberty Lobby, Inc., and Willis Carto filed a diversity libel action against petitioners Jack Anderson, Bill Adkins, and Investigator Publishing Co. for articles portraying them as neo-Nazi, anti-Semitic, racist, and Fascist. Petitioners moved for summary judgment, asserting that respondents were public figures and actual malice was absent. The District Court granted summary judgment, but the Court of Appeals reversed as to nine statements, holding that the clear and convincing evidence standard for actual malice was irrelevant at the summary judgment stage.
Issue
This case presents the question whether the clear-and-convincing-evidence requirement must be considered by a court ruling on a motion for summary judgment under Rule 56 of the Federal Rules of Civil Procedure in a case to which New York Times applies.
Holding
We now reverse. We conclude that the determination of whether a given factual dispute requires submission to a jury must be guided by the substantive evidentiary standards that apply to the case.
Rule
When determining if a genuine factual issue as to actual malice exists in a libel suit brought by a public figure, a trial judge must bear in mind the actual quantum and quality of proof necessary to support liability under New York Times. Thus, in ruling on a motion for summary judgment, the judge must view the evidence presented through the prism of the substantive evidentiary burden.
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