New York Times v. Sullivan
| The New York Times Co. v. Sullivan | |
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| Argued January 6, 1964 Decided March 9, 1964 |
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| Full case name | The New York Times Company v. L. B. Sullivan |
| Citations | 376 U.S. 254 (more)
84 S. Ct. 710; 11 L. Ed. 2d 686; 1964 U.S. LEXIS 1655; 95 A.L.R.2d 1412; 1 Media L. Rep. 1527
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| Prior history | Judgment for plaintiff, Circuit Court, Montgomery County, Alabama; motion for new trial denied, Circuit Court, Montgomery County; affirmed, 144 So. 2d 25 (Ala. 1962); certiorari granted, 371 U.S. 946 (1963) |
| Holding | |
| The First Amendment, as applied through the Fourteenth, protected a newspaper from being sued for libel in state court for making false defamatory statements about the official conduct of a public official, because the statements were not made with knowing or reckless disregard for the truth. Supreme Court of Alabama reversed and remanded. | |
| Court membership | |
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| Case opinions | |
| Majority | Brennan, joined by Warren, Clark, Harlan, Stewart, White |
| Concurrence | Black, joined by Douglas |
| Concurrence | Goldberg, joined by Douglas |
| Laws applied | |
| U.S. Const. amends. I, XIV | |
New York Times Co. v. Sullivan, 376 U.S. 254 (1964), was a landmark United States Supreme Court case that established the actual malice standard, which has to be met before press reports about public officials can be considered to be defamation and libel; and hence allowed free reporting of the civil rights campaigns in the southern United States. It is one of the key decisions supporting the freedom of the press. The actual malice standard requires that the plaintiff in a defamation or libel case, if he is a public figure, prove that the publisher of the statement in question knew that the statement was false or acted in reckless disregard of its truth or falsity. Because of the extremely high burden of proof on the plaintiff, and the difficulty of proving the defendant's knowledge and intentions, such claims by public figures rarely prevail.
Before this decision, there were nearly US $300 million in libel actions from the Southern states outstanding against news organizations, as part of a focused effort by Southern officials to use defamation lawsuits as a means of preventing critical coverage of civil rights issues in out-of-state publications. The Supreme Court's decision, and its adoption of the actual malice standard, reduced the financial hazard from potential defamation claims, and thus countered the efforts by public officials to use these claims to suppress political criticism.
On March 29, 1960, The New York Times carried a full-page advertisement titled "Heed Their Rising Voices", paid for by the "Committee to Defend Martin Luther King and the Struggle for Freedom in the South". In the advertisement, the Committee solicited funds to defend Martin Luther King, Jr. against an Alabama perjury indictment. The advertisement described actions against civil rights protesters, some of them inaccurately, some of which involved the police force of Montgomery, Alabama. Referring to the Alabama State Police, the advertisement stated: "They have arrested [King] seven times..." However, at that point he had been arrested four times. Although African-American students staged a demonstration on the State Capitol steps, they sang the National Anthem and not My Country, 'Tis of Thee. Although the Montgomery Public Safety commissioner, L. B. Sullivan, was not named in the advertisement, Sullivan argued that the inaccurate criticism of actions by the police was defamatory to him as well, due to his duty to supervise the police department.
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