New York Times Co. v Sullivan Case Brief
Facts
The plaintiff
was a Commissioner of Montgomery, Alabama. He filed a case because he claimed
that he had been defamed through an ad on the newspaper. More specifically, he
claimed that a full-page advertisement that was placed in the New York Times
was referring to himself. It should be noted, though, that there was no
particulars in the ad that would point to him specifically. Even the publishers
at the New York Times made a statement that, in effect, told Sullivan that they
had no idea why he would think that it was him at all. They, in effect, told
him that it was not about him. They even invited him to let them know which
parts of the advertisement he presumed to be pertaining to him. It is of note
as well that some of the details in the advertisement were admittedly false.
The Commissioner
demanded that the advertisement be revoked, but the jury was of the opinion
that the ad, although libelous intrinsically, was not to be retracted since
there was no proof of the malicious intent of the creator. Because of this, the
defendant Commissioner made an appeal to the Supreme Court.
Procedural History
The case was
started at the Alabama Supreme Court and was decided upon by the United States
of America Supreme Court.
Issue
The issue was
whether or not a public officer can recover damages from libelous statements in
relation to his official conduct.
Rule/s
The Constitution
bars public officials from recovering damages for statements that are
defamatory in character but which are made in relation to their official
conduct. The exception is if it is proven that such statements were uttered
with an actual knowledge that such words were false and were still deliberately
said.
Application
The press is and
should be free. The concept of freedom of expression is embodied by the press. These
are guaranteed by both the First as well as the Fourteenth Amendments of the
Constitution. In this case, the Court examined the definition of a libelous
publication per se. It stated that a publication is libelous if it tends to
cause injury to person in various aspects as in his reputation. It is also
libelous if it is intended to cause public contempt towards the person in
question.
The Court
established that errors in statements should not be so closely examined as to
nitpick and be to scrutinous.it is but human nature to make mistakes. The
freedom of speech is very important for the creation of a free society and thus
must be preserved at all costs.
The Court stated
that in support of the aforementioned Constitutional guarantees of freedom of
speech, it is important that there be created federal laws which prohibits the
very wrong that the petitioner wishes to accomplish. The press must be
protected in this case. There should be enactments which will prevent a public
official for suing and or recovering damages for having been subjected to a
defamatory statement or falsehood but which are in relation to their line of
duty. It was established that there could only be an award or recovery of
damages if and only if there is evidence of the publisher or speaker having
made such statements with deliberate malice or if there is a blatant disregard
of the veracity of the statements.
Conclusion
The Court, in
this case, upheld the freedom of the speech of the press and preserved the
right of the press to criticize those who are public officials as long as there
is no malice is actively involved.
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