Time, Inc. v. Hill Case Brief

Why is the case important?

Defendants published an article and reenacted a play about Plaintiff and his family being held hostage. The article and play were false, but were portrayed by Defendant to be the truth. Plaintiff sued Defendant for false light.

Facts of the case

“In 1952, three escaped convicts took James Hill, his wife, and their five children hostage in their Whitemarsh, Pennsylvania, home. After nineteen hours, the family was released unharmed. The convicts were later apprehended in a violent clash with police during which two of them were killed. In 1953, Joseph Hays’ published a novel based on the Hill family’s ordeal. When the novel was subsequently made into a play, Life Magazine (“”Life””) printed an article about the play that mirrored many of its inaccuracies concerning the Hill family’s experience. Alleging that it deliberately misrepresented his story, Hill sought damages against Life. On appeal from an adverse ruling, the Appellate Division of the New York Supreme Court remanded for a new trial where a reduced adverse ruling was imposed on Life. Following an unsuccessful appeal in the New York Court of Appeals, the Supreme Court granted Life’s owner, Time Inc. (“”Time””) certiorari.”

Question

Does a publication of a false report on a matter of public interest need only meet the New York Times test of actual malice to permit recovery in a lawsuit for false light?

Answer

Yes. Reversed and remanded.
* Exposure of the self to others in varying degrees is a concomitant of life in a civilized community. The risk of their exposure is an essential incident of life in a society, which places a primary value on freedom of speech and of press. A broadly defined freedom of the press assures the maintenance of our political system. Fear of litigation will inevitably create the danger that the legitimate utterance will be penalized. However, constitutional guarantees cannot tolerate sanctions against calculated falsehood without significant impairment of their essential function.
* The evidence in this case reasonably would support a jury finding of either innocent or merely negligent misstatement by Defendant, or a finding that Defendant portrayed the play as a re-enactment of the Hill family’s experience reckless of the truth or with actual knowledge that the portrayal was false.

Conclusion

On appeal, judgment was reversed and remanded. In support of its ruling, the Supreme Court held that the constitutional protections for speech and press precluded the application of the statute to redress false reports of matters of public interest in the absence of proof that appellant published the report with knowledge of its falsity or in reckless disregard of the truth. The Court noted that the evidence could have supported either a jury finding of innocent or merely negligent misstatement by appellant, or a finding of appellant’s reckless disregard of the truth or actual knowledge of falsity. The jury instruction given by the lower court, however, failed to confine the jury to a verdict of liability based upon a finding that the statements in the article were made with knowledge of their falsity or in reckless disregard of the truth.

  • Case Brief: 1967
  • Appellant: Time Inc.
  • Appellee: James J. Hill
  • Decided by: Warren Court

Citation: 385 US 374 (1967)
Argued: Apr 27, 1966
ReArgued: Oct 18 – 19, 1966
Decided: Jan 9, 1967