Anderson v. Liberty Lobby, Inc.

91 L. Ed. 2d 202 · Supreme Court of the United States · 1986

Facts

Liberty Lobby, Inc. and Willis Carto, identified as public figures, sued Jack Anderson and others for libel over articles portraying them as neo-Nazi and anti-Semitic. The District Court granted summary judgment for the defendants, finding no actual malice, but the Court of Appeals reversed in part, holding that the 'clear and convincing' evidence standard for actual malice did not apply at the summary judgment stage.

Issue

Must the 'clear and convincing evidence' standard for proving actual malice in a libel suit brought by a public figure be considered by a court when ruling on a motion for summary judgment?

Holding

Yes, the clear and convincing evidence requirement must be considered by a court ruling on a motion for summary judgment in a case to which the New York Times actual malice standard applies. The Supreme Court reversed the Court of Appeals' decision.

Rule

When ruling on a motion for summary judgment, a court must consider the substantive evidentiary standard of proof that would apply at trial. In a libel case involving a public figure, the judge must determine whether the evidence is such that a reasonable jury could find actual malice with 'convincing clarity' to defeat summary judgment.

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Case brief last reviewed 2026-02-06. Prepared by CaseReader from the published opinion.