New York Times v. Sullivan (1964) is a significant United States Supreme Court case which held that the court must find evidence of actual malice before it can hold the press guilty for defamation and libel against a public figure. This was a landmark Supreme Court decision regarding freedom of the press.
New York Times v. Sullivan established the actual malice standard which requires the plaintiff to prove that the publisher was aware that the statement was false and published it anyway. This places a very high burden of proof on the plaintiff in a libel cases. The concept of public figures is important in freedom of the press cases. A public figure is a person that puts themselves in the eye of the public, such as a politician or celebrity. These individuals have the burden of proof in defamation and libel cases.
This was a very controversial issue at the time because of the highly publicized civil rights cases in the South, where many Southerners continued to practice segregation. News organizations that desired to run these stories were often hesitant due to fear that they would be dragged into a libel suit. When the Supreme Court held in New York Times v. Sullivan that the Times was not guilty of libel, it opened up many opportunities for news sources to print stories about the civil rights cases in the South. In 1960, the New York Times ran an advertisement about Martin Luther King that contained inaccuracies about the conduct of the Montgomery, Alabama police department.
The newspaper alleged that the police department took unlawful action against civil rights protesters. The Montgomery Police Commissioner, L. B. Sullivan wrote a letter to the New York Times demanding they run a retraction of the story. When the Times refused, Sullivan brought suit against the newspaper and received damages. The Times still did not publish a retraction because they claimed the advertisement did not specifically name Sullivan and was not a condemnation of his conduct.
In New York Times v. Sullivan, the United States Supreme Court held that the actions of the New York Times were not sufficient for a libel suit. The New York Times was protected under the freedom of the press clause of the First Amendment, which states that “Congress shall make no law…abridging the freedom of speech, or of the press”. The Court ruled under the actual malice standard. This would require Sullivan to prove that the New York Times knew the statements against him were untrue and acted recklessly
through a conscious lack of investigation by publishing them.
The Supreme Court determined that the Alabama State court’s award of punitive damages to Sullivan was not appropriate due to the Times’ Constitutional right to freedom of the
press. New York Times v. Sullivan was the first time that the Court used the concept of actual malice in the freedom of the press case. The actual malice standard requires the
plaintiff to prove that the plaintiff had knowledge of the untruth of the statements published, rather than the plaintiff having to prove the truth of the statements.