New York Times Co. v. Sullivan

New York Times Co. v. Sullivan, 376 U.S. 254 (1964), is a landmark decision of the United States Supreme Court.

The New York Times published a full-page advertisement describing civil rights protests in Montgomery, Alabama. The ad contained minor factual inaccuracies about the police. Montgomery Police Commissioner L.B. Sullivan sued for libel and won a $500,000 judgment under Alabama law. The Times appealed, arguing that the law violated the First Amendment.

Significance

Justice Brennan’s unanimous opinion reversed the judgment and announced the ‘actual malice’ standard for defamation cases involving public officials. Public officials cannot recover damages for defamation unless they prove the statement was made with ‘knowledge that it was false or with reckless disregard of whether it was false or not.’ The decision dramatically expanded press freedom by protecting robust criticism of government officials. The actual malice standard was later extended to public figures in Curtis Publishing Co. v. Butts (1967).

Category

US Federal Case Law