Why is the case important?
During a televised speech, the Defendant, St. Amant (Defendant), quoted material from a third person that falsely accused the Plaintiff, Thompson (Plaintiff), of criminal activities. The trial court found in favor of the Plaintiff. The appellate court reversed. The Louisiana Supreme Court affirmed the trial court’s decision.
Facts of the case
“On June 27, 1962, Phil St. Amant, a candidate for public office, made a television speech in Baton Rouge, Louisiana. During this speech, St. Amant accused his political opponent of being a Communist and of being involved in criminal activities with the head of the local Teamsters Union. Finally, St. Amant implicated Herman Thompson, an East Baton Rouge deputy sheriff, in a scheme to move money between the Teamsters Union and St. Amant’s political opponent.Thompson successfully sued St. Amant for defamation. Louisiana’s First Circuit Court of Appeals reversed, holding that Thompson did not show St. Amant acted with “malice.” Thompson then appealed to the Supreme Court of Louisiana. That court held that, although public figures forfeit some of their First Amendment protection from defamation, St. Amant accused Thompson of a crime with utter disregard of whether the remarks were true. Finally, that court held that the First Amendment protects uninhibited, robust debate, rather than an open season to shoot down the good name of anyone who happens to be a public servant.”
Was the Supreme Court of Louisiana correct in its determination that defendant acted with reckless disregard for the truth?
No. Judgment reversed and remanded.
* The Supreme Court accepts the Louisiana courts determinations that the material published was false and that the Plaintiff was a public official for the purpose of this case. Therefore, the actual malice standard is applicable. It is clear that the Defendant had no personal knowledge of the Plaintiff’s activities, but rather relied only on the union member’s affidavit. He failed to verify the information, mistakenly believing that he had no responsibility for the broadcast because he was quoting someone else’s words.
* In order to meet the actual malice standard, the Defendant must have a high degree of awareness of the statements probable falsity. This standard is not measured by whether a reasonably prudent man would have published the material or would have investigated before publishing. Rather, there must be sufficient evidence to show that the Defendant entertained serious doubts as to the truth of his publication.
* A defendant cannot insure a favorable verdict by simply stating that he published with a belief that the statement was true. The jury must instead determine if the publication was made in good faith. However, in this case the evidence against the Defendant was insufficient to meet the reckless disregard requirement for actual malice.
On certiorari, the Supreme Court of the United States reversed and remanded the case. In an opinion by White, J., expressing the views of six members of the court, the court ruled that the reasons given by the Supreme Court of Louisiana in support of its holding—that St. Amant relied solely on an affidavit given by a union member without verifying the information, that he gave no consideration to whether or not the statements defamed Thompson and went ahead heedless of the consequences, and that he mistakenly believed he had no responsibility for broadcast—fell short of proving St. Amant’s reckless disregard for the accuracy of his statements about Thompson. The record showed that St. Amant’s failure to investigate his information did not establish bad faith under the circumstances. Of particular significance was the Court’s holding that reckless conduct was not measured by whether a reasonably prudent man would have published, or would have investigated before publishing, and that the finder of fact must determine whether the defamatory publication was made in good faith.
- Case Brief: 1968
- Petitioner: Phil A. St. Amant
- Respondent: Herman A. Thompson
- Decided by: Warren Court
Citation: 390 US 727 (1968)
Argued: Apr 4, 1968
Decided: Apr 29, 1968