New York Times Co. v. Sullivan

11 L. Ed. 2d 686 · Supreme Court of the United States · 1964

Facts

L. B. Sullivan, an elected Commissioner of Montgomery, Alabama, responsible for the Police Department, sued the New York Times and four Alabama clergymen for libel. The suit stemmed from a full-page advertisement published in the Times on March 29, 1960, titled “Heed Their Rising Voices,” which described non-violent student demonstrations and alleged a "wave of terror" by authorities. The advertisement contained several factual inaccuracies regarding police actions in Montgomery and events concerning Dr. Martin Luther King, Jr. Although Sullivan was not named, he contended that references to "police" implicated him as the Commissioner in charge. The Times published the ad after receiving certification from a known individual, but without independently verifying its accuracy against its own news files. Sullivan demanded a retraction, which the Times did not issue for him, but later did for the Governor of Alabama.

Issue

To what extent do constitutional protections for speech and press limit a State’s power to award damages in a libel action brought by a public official against critics of his official conduct? Does Alabama's rule of liability, as applied to this case, abridge the freedom of speech and of the press guaranteed by the First and Fourteenth Amendments?

Holding

The Court reversed the judgment, holding that Alabama's rule of law was constitutionally deficient for failing to provide necessary safeguards for freedom of speech and press in libel actions by public officials. The evidence presented was constitutionally insufficient to support the judgment under the proper safeguards.

Rule

The First and Fourteenth Amendments require a federal rule prohibiting a public official from recovering damages for a defamatory falsehood relating to his official conduct unless he proves "actual malice." "Actual malice" means the statement was made with knowledge that it was false or with reckless disregard of whether it was false or not. This rule is essential because erroneous statements are inevitable in free debate, and requiring critics to guarantee truth would lead to self-censorship, thereby stifling robust public discussion. Furthermore, criticism of government cannot be transmuted into personal libel of officials solely based on their official position.

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