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, sued The New York Times and four individual clergymen for libel over a full-page advertisement that criticized police actions against civil rights protestors. Although Sullivan was not named, he contended the advertisement defamed him in his capacity as the commissioner overseeing the police department. An Alabama jury awarded Sullivan $500,000, and the Alabama Supreme Court affirmed the judgment.
Issue
To what extent do the 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?
Holding
The Supreme Court reversed the judgment, holding that the Alabama rule of law was constitutionally deficient for failing to provide the safeguards for freedom of speech and of the press required by the First and Fourteenth Amendments. The Court found the evidence presented was constitutionally insufficient to support the judgment for Sullivan under the proper legal standard.
Rule
A public official cannot recover damages for a defamatory falsehood relating to his official conduct unless he proves that the statement was made with "actual malice"—that is, with knowledge that it was false or with reckless disregard of whether it was false or not.
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