Facts of the case
During the Civil Rights movement of the 1960s, the New York Times published an ad for contributing donations to defend Martin Luther King, Jr., on perjury charges. The ad contained several minor factual inaccuracies. The city Public Safety Commissioner, L.B. Sullivan, felt that the criticism of his subordinates reflected on him, even though he was not mentioned in the ad. Sullivan sent a written request to the Times to publicly retract the information, as required for a public figure to seek punitive damages in a libel action under Alabama law.When the Times refused and claimed that they were puzzled by the request, Sullivan filed a libel action against the Times and a group of African American ministers mentioned in the ad. A jury in state court awarded him $500,000 in damages. The state supreme court affirmed and the Times appealed.
Why is the case important?
The Alabama Supreme Court of upheld a judgment awarding the Respondent, L.B. Sullivan (Respondent), damages in a civil libel action. The Petitioner, the New York Times (Petitioner), appealed.
Did Alabama’s libel law, by not requiring the Respondent to prove that the speech in question was motivated by actual malice, unconstitutionally infringe on the First Amendment’s freedom of speech and freedom of press protections?
Yes. The court ruled that the First Amendment of the United States Constitution (Constitution) protects the publication of all statements, even false ones, about the conduct of public officials except when statements are made with actual malice (with knowledge that they are false or in reckless disregard to truth or falsity). Specifically, the rule of law applied by the Alabama courts was constitutionally deficient for failure to provide the Petitioner the safeguards for freedom of speech and of the press that were guaranteed by the First and Fourteenth Amendments of the Constitution in a libel action brought by a public official against critics of his official conduct.
The Court held that the First Amendment required a rule that prohibited a public official from recovering damages for a defamatory falsehood relating to the public official’s official conduct unless the official can prove that the statement was made with actual malice. The Court defined actual malice as knowledge that the defamatory statement was false or made with reckless disregard of whether it was false or not. The Court held that no evidence was presented to show that the New York Times acted with actual malice in publishing the advertisement, and as a result, could not be held liable in an action for libel.
- Advocates: Herbert Wechsler For the Petitioner William P. Rogers for the Petitioner Samuel R. Pierce, Jr. for the Petitioner M. Roland Nachman, Jr. for the Respondent
- Petitioner: New York Times Company
- Respondent: Sullivan
- DECIDED BY:Warren Court
- Location: New York Times Office
|Citation:||376 US 254 (1964)|
|Argued:||Jan 6 – 7, 1964|
|Decided:||Mar 9, 1964|