New York Times v. Sullivan (1964)

Facts of Case:

After a student-led protest against segregation occurred in the South, the New York Times ran a full page ad entitled, “Heed Their Rising Voices.” Some of the specifics of the advertisement were false, such as the number of times Martin Luther King was jailed. L.B. Sullivan, the Montgomery city commission field a libel suit against the newspaper, claiming the allegations against the Montgomery police department defamed him personally. Though the advertisement did not name Sullivan directly, he claimed it was indirectly related to him because he was responsible for the police.

The jury found the New York Times ad libelous without proof of malice and awarded Sullivan $500,000 in damages. The New York Times appealed.

Legal Issue/Decision:

The question the Supreme Court Justices had to answer was whether the New York Times is liable for defamation for printing an advertisement, which criticized a public official’s official conduct. The judgment was reversed. The New York Times was protected by the First and Fourteenth Amendment. Also, Sullivan was prohibited from recovering damages unless malice could be proven.

Analysis:

This was the first case to rule that the First Amendment covers libelous statements. The Court ruled in favor of the New York Times because they were not maliciously going after L.B Sullivan. They were trying to make a general point about the segregation issues in the South, and he happened to take it a little too personally. This case will take precedence in other cases we look at and in future cases that have yet to occur.

Questions:

  1. Have you ever felt like news coverage or an advertisement reflected poorly on you or something you were a part of? What did you do about it? Examples – Bowling Green State University, a sorority or fraternity, work place, etc.
  2. What do you think today’s society would be like if the case held it’s original standing?
  3. How would this case compare to Hazelwood School District v. Kuhlmeier (1988) if the stories on teen pregnancy and divorce were printed?