Harte-Hanks Communications, Inc. v. Connaughton (1988)
- Docket
- 88-10
- Decided
- 1988-01-01
Summary
Question: Did the newspaper’s reporting of the scandal exhibit “actual malice”? Conclusion: Yes. Justice John Paul Stevens delivered the opinion of the 9-0 majority. The Court held that a public figure plaintiff in a libel case must prove that the libelous statement was false or made without any regard for its truth. The fact that the newspaper failed to interview one of the main witnesses to the supposed bribery strongly indicated a disregard for the truth of the story. Although there were many reasons to doubt the truth of the accusations against Connaughton, the newspaper failed to properly investigate, so the act of publishing the story constituted actual malice. In his concurring opinion, Justice Byron R. White wrote that the Court did not overstep its bounds by looking at the facts of the case in order to determine whether or not the newspaper exhibited actual malice. Justice Harry A. Blackmun wrote a concurring opinion where he argued that the Court might have looked at the facts of the case differently if the petitioner had not abandoned the defense that Harte-Hanks believed the report to be true. He also wrote that the failure of the majority opinion to mention the actual content of the article in question does not mean that the Court did not consider it relevant. Justice Anthony M. Kennedy concurred with the majority’s decision because he did not feel it inconsistent with the analysis Justice Antonin Scalia provided in his concurrence. Justice Antonin Scalia wrote an opinion concurring in judgment where he argued that the majority’s opinion unnecessarily focuses its analysis on what the trial court jury found in favor of the plaintiff, rather than exercising its own independent judgment.