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 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 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 lawabridging 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 courts 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 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.
Courtesy constitiution.laws.com