Farmers Educational & Cooperative Union of America v. WDAY, Inc. (1958)
- Docket
- 248
- Decided
- 1958-01-01
Summary
Question: Does the Federal Communications Act of 1934 prohibit a broadcasting station from removing defamatory statements in speeches broadcast by legally qualified candidates for office? If so, does the station have federal immunity from liability for libelous statements in the broadcast? Conclusion: Yes, yes. Justice Hugo L. Black delivered the opinion of the 5-4 majority. The Court held that the censorship prohibited by the Federal Communications Act of 1934 was defined broadly and included the removal of objectionable material from a political speech. Permitting broadcasting stations to engage in this type of censorship would undermine the purpose the Act was meant to serve. The Court also held that holding the station liable for any defamatory statement made during the broadcast of a political speech would allow liability for conduct that the statute requires. While Congress did not explicitly include station immunity in the Act, the Federal Communications Commission, the body in charge of administering the Act, has long upheld the doctrine of station immunity. Justice Felix Frankfurter dissented and argued that, unless Congress explicitly granted stations immunity from state libel laws, state law trumps any implied federal immunity. Since Congress has not granted any explicit immunity, and the legislative history does not indicate that they intended to do so, the state laws stand. He also argued that the precedent set by the Court supports the state unless federal laws explicitly intercede. Justice John M. Harlan, Justice Charles E. Whittaker, and Justice Potter Stewart joined in the dissent.