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St. Amant v. Thompson - 390 U.S. 727, 88 S. Ct. 1323 (1968)

Rule:

Reckless conduct is not measured by whether a reasonably prudent man would have published, or would have investigated before publishing. There must be sufficient evidence to permit the conclusion that the defendant in fact entertained serious doubts as to the truth of his publication. Publishing with such doubts shows reckless disregard for truth or falsity and demonstrates actual malice.

Facts:

Respondent Thompson, a deputy sheriff of a Louisiana parish, filed a defamation action in Louisiana state court action against petitioner St. Amant, a candidate for public office after St. Amant, in a televised speech, implicated Thompson in criminal conduct with a local labor union officer. The trial judge ruled in Thompson's favor and awarded him damages. The trial judge, after considering New York Times Co. v. Sullivan, which had been decided after the trial, denied St. Amant's motion for a new trial. On St. Amant's appeal, the Louisiana Court of Appeal reversed because the record failed to show that defendant had acted with actual malice, as required by New York Times Co. v. Sullivan. The Supreme Court of Louisiana reversed the intermediate appellate court, holding that there was sufficient evidence that St. Amant recklessly disregarded whether the defamatory statements were true or false. The Supreme Court of the United States granted St. Amant's petition for certiorari.

Issue:

Was the evidence in the case sufficient to permit the conclusion that St. Amant acted in reckless disregard of whether the statements about Thompson were false or not?

Answer:

No.

Conclusion:

On certiorari, the Supreme Court of the United States reversed and remanded the case. In an opinion by White, J., expressing the views of six members of the court, the court ruled that the reasons given by the Supreme Court of Louisiana in support of its holding—that St. Amant relied solely on an affidavit given by a union member without verifying the information, that he gave no consideration to whether or not the statements defamed Thompson and went ahead heedless of the consequences, and that he mistakenly believed he had no responsibility for broadcast—fell short of proving St. Amant's reckless disregard for the accuracy of his statements about Thompson. The record showed that St. Amant's failure to investigate his information did not establish bad faith under the circumstances. Of particular significance was the Court's holding that reckless conduct was not measured by whether a reasonably prudent man would have published, or would have investigated before publishing, and that the finder of fact must determine whether the defamatory publication was made in good faith.

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