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Concept
New York Times Co. v. Sullivan
Summary
New York Times Co. v. Sullivan, 376 U.S. 254 (1964), was a landmark U.S. Supreme Court decision ruling that the First Amendment to the U.S. Constitution's freedom of speech protections limit the ability of American public officials to sue for defamation. The decision held that if a plaintiff in a defamation lawsuit is a public official or candidate for public office, not only must they prove the normal elements of defamationpublication of a false defamatory statement to a third partythey must also prove that the statement was made with "actual malice", meaning the defendant either knew the statement was false or recklessly disregarded whether it might be false. New York Times Co. v. Sullivan is frequently ranked as one of the greatest Supreme Court decisions of the modern era.
The underlying case began in 1960, when The New York Times published a full-page advertisement by supporters of Martin Luther King Jr. that criticized the police in Montgomery, Alabama, for their treatment of civil rights movement protesters. The ad had several inaccuracies regarding facts such as the number of times King had been arrested during the protests, what song the protesters had sung, and whether students had been expelled for participating. Based on the inaccuracies, Montgomery police commissioner L. B. Sullivan sued the Times for defamation in the local Alabama county court. After the judge ruled that the advertisement's inaccuracies were defamatory per se, the jury returned a verdict in favor of Sullivan and awarded him $500,000 in damages. The Times appealed first to the Supreme Court of Alabama, which affirmed the verdict, and then to the U.S. Supreme Court, which agreed to hear the case.
In March 1964, the Court issued a 9–0 decision holding that the Alabama court's verdict violated the First Amendment. The decision defended free reporting of the civil rights movement campaigns in the southern United States. It is one of the key decisions supporting the freedom of the press.
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