New York Times Co. v. Sullivan

New York Times Co. V. Sullivan (Appeal case) 376 U.S. 254 March 9, 1964

Plaintif: New York Times Co. - (Publisher of the New York Times) on appeal from a previous decision rendered by the Supreme Court of the state of Alabama Defendant: L.B. Sullivan - Public Safety Commissioner of Montgomery, Alabama

Summary: Sullivan filed a case of libel against New York Times Co. for publishing an ad in their newspaper that allegedly pertains to him, since the supposed defamatory statements in question is reflective of his duties as the Public Safety Commissioner, who is an overseer of several responsibilities, which are also supposedly included in the ad by New York Times Co. New York Times was ordered by the supreme court of Alabama to pay Sullivan $500,000 in damages. Hence this Appeal. New York Times won the case (9-0) due to the court stressing out the factor in statements being declared as defamatory or libellous should also include malice in its intent. Thus, The previous decision of the court was retracted and so was the supposed award to Sullivan.

Facts: Plaintiff published an ad in its newspaper entitled "Heed Their Rising Voices", which was a full-page article about the demonstrations being performed by African Americans, in an attempt to stress out equality and their inclusion in the application of the Bill of Rights, and the Constitution. This historical movement was headed by Martin Luther King jr. and was considered an icon against the idea of inequality and the attacks of the white supremacy loyalists. The New York Times published in its paper that the movement was being attacked by a "Wave of Terror" particularly by the Police. The article included some false statements (according to paragraph 6 of the article, Luther King was arrested 7 times, when in fact it had only been 4, and other acts of violence pertaining to the actions of the Police). The person responsible for the actions mentioned in the article was not named. However, then plaintiff Sullivan filed a complaint and also demanded the Paper to retract its article, alleging that the article pertains to him, due to his duties as Public Safety Commissioner which includes the responsibility of being the overseer of the Police Department, Fire Department, etc. New York Times did not retract the article

due to Sullivan's demand and was even puzzled according to their statement as to why Sullivan would directly conclude that the article pertained to him. The Supreme Court of Alabama found New York Times Co. guilty of libel and ordered them to pay Sullivan $500,000 as damages

Issue: WON the court's decision and measure of libel as contained in this case infringes the freedom of speech and that of the press, as stressed by the 1st and 14th amendments.

Held: YES! The Court ruled for The Times, 9–0. The rule of law applied by the Alabama courts was found constitutionally deficient for failure to provide safeguards for freedom of speech and of the press, as required by the First and Fourteenth Amendment. The decision further held that even with the proper safeguards, the evidence presented in this case was insufficient to support a judgment for Sullivan.

Ratio: The Court of Alabama's rule on liability states that a publication is libellous if the if the words tend to injure a person in his reputation or to bring him to public contempt, is not consistent with the intent of the 1st and 14th Amendment due to the rule being too wide in its scope that it fails to provide the necessary standard of elements that a may then implicate such a publication to be libellous. Libellous material must be with malice, as to include false statements or was written and/or published with blatant disregard for the verification of the validity of the included information therein. It has to be proven in fact that Malice exists, and that it cannot be presumed. The rule used by Alabama does not require a proof in fact, thus it is inconsistent with the constitution. In this case, there was no proof of malice being present in the following stressed points: 1.) The False statements included in the article was not published with malice due to the belief of the publishers that the sponsors of the ad were trusted and regular contributors to their news paper. 2.) In no way can the article pertain to Sullivan due to the absence of his name or position in the publication in question. Therefore, previous judgement was reversed. New York Times Co. won the appeal and case.