Cases and Conflicts - Print: New York Times v. Sullivan


New York Times v. Sullivan Significance: The 1964 Supreme Court ruling in New York Times v. Sullivan played a key role in developing current libel standards. The Court ruled that public figures have a higher burden of proof in a libel case than private citizens. Public officials have to prove a libelous statement is published with malicious intent. The New York Times carried a full-page advertisement entitled, Heed Their Rising Voices for the Committee to Defend Martin Luther King and the Struggle for Freedom in the South. The advertisement suggested that public officials in the South were using violent and illegal means to try to stop the civil rights movement. Although the advertisement's claims were largely truthful, some minor factual errors were made. L. B. Sullivan, the Montgomery Alabama Police Commissioner, claimed these errors damaged his reputation and he won $500,000 in a libel case in Alabama. The case was appealed to the US Supreme Court, where the decision was unanimously reversed, saying the New York Times was not guilty of reckless disregard for the truth. The Court ruled that the importance of free debate in a democratic society was more important than factual errors that might upset or even damage public officials. To win a libel case, public officials now needed to prove that damaging statements were printed with malicious intent. The Supreme Court defined malice as "a reckless disregard for the truth, or advance knowledge of falsity." Since the ruling made it difficult for public officials to sue for libel, questions arose as to who was and who was not a public official. For further clarification, the Supreme Court eventually changed the term to public figure. The Court continues to give the mass media room for honest error, in their coverage of government officials, political candidates and other public figures. Sources: Vivian, John. The Media of Mass Communication. Fourth Edition. New York: Allyn and Bacon, 1997. p 474. Hiebert, Ray Elden, Donald F. Ungurait, and Thomas W. Bohn. Mass Media VI: An Intro to Modern Communications. New York: Longman, 1991. p 507. FindLaw Internet Legal Resources: http://caselaw.findlaw.com/cgi-bin/getcase.pl?court=US&vol=376&invol=254

New York Times v. Sullivan

Significance: The 1964 Supreme Court ruling in New York Times v. Sullivan played a key role in developing current libel standards. The Court ruled that public figures have a higher burden of proof in a libel case than private citizens. Public officials have to prove a libelous statement is published with malicious intent.

The New York Times carried a full-page advertisement entitled, Heed Their Rising Voices for the Committee to Defend Martin Luther King and the Struggle for Freedom in the South. The advertisement suggested that public officials in the South were using violent and illegal means to try to stop the civil rights movement. Although the advertisement's claims were largely truthful, some minor factual errors were made. L. B. Sullivan, the Montgomery Alabama Police Commissioner, claimed these errors damaged his reputation and he won $500,000 in a libel case in Alabama.

The case was appealed to the US Supreme Court, where the decision was unanimously reversed, saying the New York Times was not guilty of reckless disregard for the truth. The Court ruled that the importance of free debate in a democratic society was more important than factual errors that might upset or even damage public officials. To win a libel case, public officials now needed to prove that damaging statements were printed with malicious intent. The Supreme Court defined malice as "a reckless disregard for the truth, or advance knowledge of falsity."

Since the ruling made it difficult for public officials to sue for libel, questions arose as to who was and who was not a public official. For further clarification, the Supreme Court eventually changed the term to public figure. The Court continues to give the mass media room for honest error, in their coverage of government officials, political candidates and other public figures.

Sources:

Vivian, John. The Media of Mass Communication. Fourth Edition. New York: Allyn and Bacon, 1997. p 474.

Hiebert, Ray Elden, Donald F. Ungurait, and Thomas W. Bohn. Mass Media VI: An Intro to Modern Communications. New York: Longman, 1991. p 507.

FindLaw Internet Legal Resources:
http://caselaw.findlaw.com/cgi-bin/getcase.pl?court=US&vol=376&invol=254