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New York Times v. Sullivan

New York Times v. Sullivan

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 libel

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

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 State 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

New York
Times v. Sullivan was the first time that the Court used the concept of actual
malice in a 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.