Rosenbloom v. Metromedia, Inc.
29 L. Ed. 2d 296 · Supreme Court of the United States · 1971
Facts
Petitioner, a nudist magazine distributor, was arrested for selling allegedly obscene material, and respondent, a radio station, broadcast news reports characterizing the seized books as "obscene" and petitioner as a "smut merchant." After his acquittal, petitioner sued the radio station for libel under Pennsylvania law. The District Court applied state law, but the Court of Appeals applied the New York Times standard and reversed the judgment for petitioner.
Issue
Does the New York Times "knowing-or-reckless-falsity" standard apply in a state civil libel action brought by a private individual for a defamatory falsehood uttered in a news broadcast about an event of public or general interest?
Holding
Yes, the New York Times "knowing-or-reckless-falsity" standard applies to libel actions brought by private individuals when the defamatory falsehood concerns an event of public or general interest. The Court affirmed the Court of Appeals' judgment, finding that the evidence did not meet this standard.
Rule
The constitutional guarantees of freedom of speech and press require that a private individual suing a news media outlet for defamation concerning an event of public or general interest must prove by clear and convincing evidence that the defamatory falsehood was published with knowledge of its falsity or with reckless disregard of whether it was false or not.
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