Sullivan v. New York Times
Decided during a period of unrest in 1964, the U.S. Supreme Court’s Sullivan v. New York Times was a landmark case that set the standard for libel cases.
This case set the baseline test for “actual malice” in publishing. Malice is the intention to harm and is the underpinning of libel, which is a published account intended to bring damage or harm to an individual or institution.
Public figures often claim a negative newspaper or magazine account of their behavior or reputation is damaging, false, and intentional and therefore malicious and libelous, but prevailing in a court case on this charge is very challenging because it requires the plaintiff (accuser) to prove the publisher’s intent.
The U.S. Supreme Court was involved in this dispute between the New York Times and the public safety commissioner of Montgomery Alabama because state courts in Alabama had awarded him, L.B. Sullivan, $500,000 in damages for what he called libel in an advertisement in the Times. The Supreme Court said in its unanimous decision that the state courts in Alabama did not adequately protect the newspaper’s right to free speech guaranteed in the First and Fourteenth Amendments of the Constitution.
The U.S. Supreme Court is the final judge of the constitutionality of state laws.
There were many clashes between public officials and civil rights activists in Alabama and the South in the period surrounding the Civil Rights Act of 1964. Lawsuits were one tactic that officials and anti-civil rights groups employed to keep the press from reporting on the violence that met peaceful demonstrations such as marches.
When the New York Times published a full-page advertisement critical of Alabama officials and the state police for their treatment of Rev. Martin Luther King and other activists, the Montgomery Public Safety Commissioner, L.B. Sullivan, said it was an untrue personal attack on his character and claimed libel. Courts in Alabama agreed, awarding him $500,000 in his initial suit against the Times.