New York Times Co. v. Sullivan - 376 U.S. 254, 84 S. Ct. 710 (1964)

Rule:

Constitutional guarantees 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 made with reckless disregard of whether it was false or not.

Facts:

An action for libel was brought by Sullivan, a City Commissioner in Montgomery, Alabama, against the New York Times alleging that the newspaper published defamatory statements in a paid advertisement describing the maltreatment of African American students protesting segregation by police under Sullivan's supervision. Sullivan argued that he was implicated in the false and defamatory advertisement because he oversaw the City police in his official capacity as City Commissioner. Several of the allegations in the advertisement were false or exaggerated. The jury awarded damages and the judgment on the verdict was affirmed by the Supreme Court of Alabama on the grounds that the statements in the advertisement were libelous per se, false, and not privileged, and that the evidence showed malice on the part of the newspaper. The case was elevated by writ of certiorari to the Supreme Court of the United States.

Issue:

Does a public official have to prove “actual malice” before he can recover damages in a defamation action against persons criticizing their official conduct?

Answer:

Yes.

Conclusion:

The Court held that the First Amendment required a rule that prohibited a public official from recovering damages for a defamatory falsehood relating to the public official's official conduct unless the official can prove that the statement was made with actual malice. The Court defined actual malice as knowledge that the defamatory statement was false or made with reckless disregard of whether it was false or not. The Court held that no evidence was presented to show that the New York Times acted with actual malice in publishing the advertisement, and as a result, could not be held liable in an action for libel.