NEW YORK TIMES CO. v. SULLIVAN

Legal Principle at Issue

Whether Alabama's libel laws unconstitutionally infringed on the First Amendment's freedom of speech and press protections.

Action

Reversed and remanded. Petitioning party received a favorable disposition.

Facts/Syllabus

Montgomery police commissioner L. B. Sullivan, a local elected official in Alabama, brought a civil libel suit against the publisher of the New York Times and four individual black clergymen in Alabama for running an ad in the newspaper. The full-page advertisement titled "Heed Their Rising Voices", appeared in the March 29, 1960 issue of the newspaper and was paid for by the Committee to Defend Martin Luther King and the Struggle for Freedom in the South. The advertisement referred to Alabama "official authority and police power" that had "arrested" Rev. Martin Luther King Jr. "seven times" (the actual number was four) and that "truckloads of police . . . ringed the Alabama State College campus" after a protest at the state capitol (but state officials claimed there was no connection to the protest). Sullivan was not named in the advertisement, but he argued the inaccuracies were defamatory nevertheless because he supervised the police department.

The trial judge instructed the jury that such statements were "libelous per se," legal injury being implied without proof of actual damages, and that, for the purpose of compensatory damages, malice was presumed, so that such damages could be awarded against petitioners if the statements were found to have been published by them and to have related to respondent. As to punitive damages, the judge instructed that mere negligence was not evidence of actual malice, and would not justify an award of punitive damages. The judge refused to instruct that actual intent to harm or recklessness had to be found before punitive damages could be awarded, or that a verdict for respondent should differentiate between compensatory and punitive damages. The jury found in favor of Sullivan, awarding him damages of $500,000, and the State Supreme Court affirmed.

Importance of Case

A public official cannot recover damages in a civil libel suit relating to his official conduct unless he proves that the statement was made with actual malice. Actual malice is defined as “with knowledge that it was false or with reckless disregard of whether it was false.”