New York Times Company v. Sullivan (1963)

Docket
39
Decided
1963-01-01
Category
General

Summary

Question: Did Alabama's libel law unconstitutionally infringe on the First Amendment's freedom of speech and freedom of press protections? Conclusion: To sustain a claim of defamation or libel, the First Amendment requires that the plaintiff show that the defendant knew that a statement was false or was reckless in deciding to publish the information without investigating whether it was accurate. In a unanimous opinion authored by Justice Brennan, the Court ruled for the Times . When a statement concerns a public figure, the Court held, it is not enough to show that it is false for the press to be liable for libel. Instead, the target of the statement must show that it was made with knowledge of or reckless disregard for its falsity. Brennan used the term "actual malice" to summarize this standard, although he did not intend the usual meaning of a malicious purpose. In libel law, “malice” had meant knowledge or gross recklessness rather than intent, since courts found it difficult to imagine that someone would knowingly disseminate false information without a bad intent.

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