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New York Times Company v. Sullivan

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Supreme Court of the United States
New York Times Company v. Sullivan
Reference: 376 US 254
Term: 1964
Important Dates
Argued: January 6 - 7, 1964
Decided: March 9, 1964
Outcome
Supreme Court of Alabama reversed
Majority
Tom Clark • William Douglas • Earl Warren • William Brennan • Potter Stewart • Hugo Black • John Harlan • Arthur Goldberg • Byron White

New York Times Company v. Sullivan is a case decided on March 9, 1964, by the United States Supreme Court holding that an Alabama law aiming to grant public officers settlements in cases of libel was unconstitutional. The justices found the law interfered with the right to freedom of speech and freedom of the press outlined in the First Amendment, which is incorporated against the states under the Due Process Clause of the Fourteenth Amendment. The court reversed the decision of the Supreme Court of Alabama.[1][2]

HIGHLIGHTS
  • The case: During the 1960s Civil Rights movement, The New York Times published an ad asking for donations to defend Martin Luther King Jr. on perjury charges. The ad contained some nonfactual claims critical of Montgomery police officers. Montgomery Public Safety Commissioner L.B. Sullivan felt the criticism reflected on him as the officers' superior, though he was not explicitly mentioned in the ad. Sullivan filed a libel lawsuit against the Times. A jury in an Alabama court awarded him $500,000 in damages. The Alabama Supreme Court affirmed the decision. The New York Times appealed the ruling.
  • The issue: Does the Alabama libel law infringe on the First Amendment right to freedom of speech and freedom of the press?
  • The outcome: The Supreme Court reversed the decision of the Supreme Court of Alabama and held that the Alabama statute had violated the U.S. Constitution.


    • Why it matters: The Supreme Court's decision found that Alabama's state libel law violated the First Amendment. The case established the precedent that the petitioner must be able to prove actual malice to bring suit against a person or company for libel. To read more about the impact of New York Times Company v. Sullivan click here.

    Background

    During the 1960s Civil Rights movement, The New York Times published an ad asking for donations to defend Martin Luther King Jr. on perjury charges. The ad contained some factual inaccuracies about the Montgomery police. The city's public safety commissioner, L.B. Sullivan, felt that the criticism of the police reflected on him as the officers' superior, though he was not explicitly mentioned in the ad. Sullivan sent a written request to The New York Times to publicly renounce the information contained in the ad, as required under Alabama law for a public figure to seek punitive damages in a libel lawsuit. This law aims to grant public officers settlements in cases of libel. The New York Times refused to retract the ad, causing Sullivan to file a libel lawsuit against the company and a group of African American ministers mentioned in the ad.

    A jury in an Alabama court awarded L.B. Sullivan $500,000 in damages. The Alabama Supreme Court affirmed the decision. The New York Times appealed the ruling.[2]

    Oral argument

    Oral arguments were held between January 6-7, 1964. The case was decided on March 9, 1964.[1]

    Decision

    The Supreme Court decided unanimously to reverse the decision of the Supreme Court of Alabama. Justice William Brennan delivered the opinion of the court with Justices Hugo Black and Arthur Goldberg writing concurring opinions, both joined by William Douglas.[2]

    Opinions

    Opinion of the court

    Justice William Brennan, writing for the court, argued that there was not enough evidence to convict The New York Times of actual malice:[2]

    “ As to the Times, we similarly conclude that the facts do not support a finding of actual malice. The statement by the Times' Secretary that, apart from the padlocking allegation, he thought the advertisement was 'substantially correct,' affords no constitutional warrant for the Alabama Supreme Court's conclusion that it was a 'cavalier ignoring of the falsity of the advertisement [from which] the jury could not have but been impressed with the bad faith of The Times, and its maliciousness inferable therefrom.'


    The statement does not indicate malice at the time of the publication; even if the advertisement was not 'substantially correct' -- although respondent's own proofs tend to show that it was -- that opinion was at least a reasonable one, and there was no evidence to impeach the witness' good faith in holding it. The Times' failure to retract upon respondent's demand, although it later retracted upon the demand of Governor Patterson, is likewise not adequate evidence of malice for constitutional purposes.[3]

    		”
    —William Brennan, majority opinion in New York Times Company v. Sullivan[2]


    Concurring opinions

    Justice Hugo Black wrote a concurring opinion along with Justice William Douglas, arguing that the Alabama statute violated the First and Fourteenth Amendments:

    “ I base my vote to reverse on the belief that the First and Fourteenth Amendments not merely 'delimit' a State's power to award damages to 'public officials against critics of their official conduct,' but completely prohibit a State from exercising such a power. The Court goes on to hold that a State can subject such critics to damages if 'actual malice' can be proved against them. 'Malice,' even as defined by the Court, is an elusive, abstract concept, hard to prove and hard to disprove. The requirement that malice be proved provides, at best, an evanescent protection for the right critically to discuss public affairs, and certainly does not measure up to the sturdy safeguard embodied in the First Amendment.[3] ”
    —Hugo Black, concurring opinion in New York Times Company v. Sullivan[2]

    Justice Arthur Goldberg wrote a concurring opinion along with Justice William Douglas, arguing that the Alabama statute infringed on the freedom of speech and the freedom of the press:

    “ In my view, the First and Fourteenth Amendments to the Constitution afford to the citizen and to the press an absolute, unconditional privilege to criticize official conduct despite the harm which may flow from excesses and abuses. The prized American right 'to speak one's mind,' cf. Bridges v California, 314 U. S. 252, 314 U. S. 270, about public officials and affairs needs 'breathing space to survive,' NAACP v. Button, 371 U. S. 415, 371 U. S. 433. The right should not depend upon a probing by the jury of the motivation of the citizen or press. [3] ”
    —Arthur Goldberg, concurring opinion in New York Times Company v. Sullivan[2]

    Impact

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    New York Times Company v. Sullivan held that Alabama's state libel law violated the First Amendment. The case established the precedent that a petitioner must be able to prove a person or organization acted with actual malice in order to bring a libel suit.[1][2]

    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 Oyez, "New York Times Company v. Sullivan," accessed August 3, 2022
    2. ↑ 2.0 2.1 2.2 2.3 2.4 2.5 2.6 2.7 Justia, "New York Times Co. v. Sullivan, 376 U.S. 254 (1964)," accessed August 3, 2022
    3. ↑ 3.0 3.1 3.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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