New York Times V. Sullivan

3 September 2022
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NEW YORK TIMES v. SULLIVAN
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This case is about a full-page ad alleging the arrest of Rev. Martin Luther King Jr. for perjury in Alabama. The false statement's intention was to destroy King's effort to integrate public facilities and encourage black Americans to vote. Mr. Sullivan, the Montgomery city commissioner, issued a LIBEL SUIT against NYT and 4 blacks listed as endorsers of the ad, claiming that the allegations against Montgomery police defamed him personally. However, Sullivan DIDN'T HAVE TO PROVE THAT HE HARMED UNDER ALABAMA LAW.
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QUESTION
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Did Alabama's libel law unconstitutionally infringe the 1st Amendment's freedom of speech and freedom of press protections, by not requiring Sullivan to prove that an ad caused him personal harmed and dismiss the same as untruthful due to factual error?
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UNINIMITY DECISION (for NYT)
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The Court held that the 1st Amendment protects all the statement, even false ones, about the conduct of public official except when the statement is made with actual malice. Under this standard, Sullivan Case collapsed.
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ACTUAL MALICE
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It is the knowledge that the statements are FALSE or IN RECKLESS DISREGARD OF ITS TRUTH OR FALSITY.
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CASE COMMENTARY
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In NYT v. Sullivan, the evidence was constitutionally insufficient to support the judgment to respondent, since it failed to support finding that the statements were made with actual malice or that related to respondent.
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JUSTICE GOLDBERG's concurrence (joined by JUSTICE DOUGLAS)
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The 1st and 14th 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 Constitution [1st and 14th Amendments] accords citizens and press an unconditional freedom to criticize official conduct. Therefore, allegedly defamatory statements related to official conduct, the judgments for libel cannot constitutionally be sustained.
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JUSTICE BLACK
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The effective functioning of a free government like ours depends largely on the force of an informed public opinion. Such an informed understanding depends of course, on the freedom people have to applaud or to criticize the way public employees do their jobs, from the least to the most important.