New York Times v. Sullivan

Jul 9, 2024

New York Times v. Sullivan: Key Points

Background

  • Libel Law Origins: Inherited from English common law.
  • Civil Rights Era: Anti-civil rights activists used it against the movement.
    • Example: Martin Luther King Jr.'s anger in mountaintop speech over misuse of law to stop protests.
    • Methods: Using injunctions (prior restraint) and defamation/libel suits against northern papers.

Targeting the Press

  • Northern Papers: Sued for defamation just for reporting true events such as bombings, lynchings, and beatings.
  • Outcome: All-white juries led to successful anti-civil rights lawsuits, with significant financial penalties aimed at bankrupting these papers.

Supreme Court Intervention

  • Revision of Libel Law: Complete overhaul making it harder to win libel suits in the US.
  • Broad Scope: Applies not just to professional journalism but also to personal publications (e.g., Facebook, blogs).
  • Federal Involvement: Shifted libel law responsibility from state courts to federal courts, emphasizing First Amendment implications.

Key Changes and Implications

  • Constitutionalization: Libel law linked to First and Fourteenth Amendments.
  • Common Law and Statutory Law: Previously governed by state-level laws like statute of limitations.
  • Elimination of Strict Liability: Public officials must prove 'actual malice,' making it hard for them to win libel suits.
    • Actual Malice: Knowledge of falsity or reckless disregard for the truth.
  • Truth as Absolute Defense: If the reported information is true, the case is dismissed automatically.

Historical Context

  • Alien and Sedition Acts: Past laws made it a crime to criticize the government, conflicting with First Amendment protections.
  • First Amendment Duty: Americans are expected to criticize the government when it is wrong.

Further Implications

  • Virginia Board of Pharmacy: Case pointed towards future protections, including for advertisements. Initial advertisement in question was by civil rights ministers calling for justice.
  • Next Steps: More innovations in First Amendment law during the era to be discussed in upcoming content.