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Law School Case Brief

Curtis Pub. Co. v. Butts - 388 U.S. 130

Rule:

The constitutional guarantees of freedom of speech and press require a federal rule that prohibits a public official from recovering damages for a defamatory falsehood relating to his official conduct unless he proves that the statement was made with "actual malice," that is, with knowledge that it was false or with reckless disregard of whether it was false or not.

Facts:

Appellant publishers, in separate and unrelated actions, sought review of judgments from the Court of Appeals. The court prohibited a public official from recovering damages for defamatory falsehoods relating to his official conduct absent actual malice. The court reviewed two cases to consider the impact of its decision that the constitutional guarantees of freedom of speech and press required a federal rule that prohibited a public official from recovering damages for a defamatory falsehood relating to his official conduct unless he proved that the statements was made with actual malice on libel actions instituted by persons who're not public officials, but were public figures involved in issues in which the public had an important interest.

Issue:

Whether a public figure who is not a public official could recover damages for a defamatory falsehood?

Answer:

Yes.

Conclusion:

The Court concluded that these libel actions could not be left entirely to state libel laws, unlimited by any overriding constitutional safeguard, but that the rigorous requirements of the Court's decision regarding public officials was not the only appropriate accommodation of the conflicting interests at stake. The Court held that a public figure who was not a public official could recover damages for a defamatory falsehood, whose substance made substantial danger to reputation apparent, on a showing of highly unreasonable conduct that constituted an extreme departure from the standards of investigation and reporting ordinarily adhered to by responsible publishers. 

The Court affirmed the judgment in favor of appellee in the first libel case and reversed the judgment for appellee in the second case as there was no indication of a severe departure from the accepted standards.

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