Title of the Case: New York Times Co. vs. Sullivan, 376 U.S.

254
Nature: CERTIORARI TO THE SUPREME COURT OF ALABAMA
Keywords: a
Summary: City Commissioner L. B. Sullivan of Montgomery, Alabama, sued New
York Times for publishing a paid political advertisement espousing racial equality
and describing police atrocities committed against students inside a college
campus. As commissioner having charge over police actions Sullivan felt that he
was sufficiently identified in the ad as the perpetrator of the outrage; consequently,
he sued New York Times on the basis of what he believed were libelous utterances
against him.
The U. S. Supreme Court speaking through Mr. Justice William J. Brennan Jr. ruled
against Sullivan holding that honest criticisms on the conduct of public officials and
public figures are insulated from libel judgments. The guarantees of freedom of
speech and press prohibit a public official or public figure from recovering damages
for a defamatory falsehood relating to his official conduct unless he proves that the
statement was made with actual malice, i.e., with knowledge that it was false or
with reckless disregard of whether it was false or not.
.

William Joseph Brennan, Jr

Facts: During the Civil Rights movement of the mid-20th century, the New

York Times published a full-page ad for contributing donations to defend

Martin Luther King, Jr. on perjury charges. The ad contained several minor
factual inaccuracies, such as the number of times that King had been
arrested and actions taken by the Montgomery, Alabama police. The city
Public Safety commissioner, L.B. Sullivan, felt that the criticism of his
subordinates reflected on him, even though he was not mentioned in the ad.
Sullivan sent a written request to the Times to publicly retract the
information, as required for a public figure to seek punitive damages in a
libel action under Alabama law.
When the Times refused and claimed that they were puzzled by the request,
Sullivan filed his libel action against the Times and a group of AfricanAmerican ministers mentioned in the ad. A jury in state court awarded him
$500,000 in damages. Curiously, the Times did eventually retract the ad's
statements when Alabama Governor John Patterson demanded it. The
newspaper felt that, while Patterson also was not named in the ad, its

comments reflected more directly on him because he represented the state

of Alabama generally.
Issue: a
Ratio:a
Ruling: Brennan held that the First Amendment did not permit a finding of liability
by Alabama courts in this context, especially considering the modest evidence that
had been presented. When a statement concerns a public figure, according to
Brennan, it is not enough to show that it is false for the press to be liable for libel.
Instead, the target of the statement must show that it was made with knowledge of
or reckless disregard for its falsity. Brennan used the term "actual malice" to
summarize this standard, although he did not intend the usual meaning of a
malicious purpose. "Malice" had a long-standing meaning within libel law that
limited it to knowledge or gross recklessness rather than intent, since courts found
it difficult to imagine that someone would knowingly disseminate false information
without a bad intent. However, it previously had been used only to determine
whether enhanced penalties, such as punitive damages, should be awarded.