Rosenbloom v. Metromedia, Inc. (1970)
- Docket
- 66
- Decided
- 1970-01-01
- Category
- General
Summary
Question: (1) Should the knowingly and recklessly false standard for defamatory statements apply to private individuals? (2) If so, is the evidence presented at trial enough to support the damages originally awarded to Rosenbloom? Conclusion: Yes, No. In a 5-3 decision, Justice William J. Brennan wrote the judgment of the court affirming the Third Circuit decision. The Supreme Court held that the knowingly and recklessly false standard applied because the story was a matter of public concern. It did not matter that Rosenbloom was a private citizen. The Court also held that the evidence in the case did not support the damages award under the proper constitutional standard. Justice Hugo L. Black wrote a special concurrence, stating that the First Amendment protected the news media from libel judgments even where the broadcaster knows their statements were false. Justice Byron R. White also wrote a special concurrence, asserting that the press have the privilege to comment on official actions of public servants, such as the police, in full detail. Justice John M. Harlan wrote a dissent, expressing that states should be free to impose a duty of reasonable care in defamation actions involving private citizens. He would remand the case for further consideration of whether Rosenbloom sustained actual harm and whether Metromedia acted with actual malice. Justice Thurgood Marshall also wrote a dissent, stating that the court should limit damages in libel actions by private citizens to actual losses. Justice William O. Douglas did not participate.