Facts of the Case
Respondents filed a libel suit against petitioners following the publication of two articles portraying respondents as racists. Petitioners, a publisher and a magazine, sought writ of certiorari to review the decision of the United States Court of Appeals for the District of Columbia Circuit, which held that the clear and convincing evidence standard did not apply to petitioners’ motion for summary judgment in a libel suit filed by respondents, a nonprofit corporation and its founder. On certiorari, the United States Supreme Court vacated the decision of the Court of Appeals and remanded for further proceedings.
Did the first warning and waiver negate the constitutional protections required by Miranda v. Arizona?
No. In a 6-to-3 opinion, the Court held that the purpose of summary judgments is to determine if the evidence is so one-sided that a party should prevail as a matter of law. Summary judgments will not lie if there is a sufficient likelihood that a reasonable jury would return a verdict favorable to the nonmoving party. In libel cases involving public entities, trial courts faced with summary judgment motions must decide whether a reasonable jury could conclude with convincing clarity that actual malice existed. The mere assertion by a plaintiff that a defendant’s summary judgment motion is deficient because a reasonable jury might disbelieve the defendant’s denial of actual malice is insufficient to warrant a grant of summary judgment without any offer of evidentiary proof to that effect. The Court reversed the appellate court’s decision and remanded for reconsideration of its summary judgment ruling.
Citation: 477 US 242 (1986)
Argued: Dec 3, 1985
Decided: Jun 25, 1986
Case Brief: 1986