Does the Constitution shield a newspaper from libel damages when it publishes false statements about a public official's conduct, absent proof of actual malice?

L.B. Sullivan, the Commissioner of Public Affairs in Montgomery, Alabama, filed a libel lawsuit against the New York Times and four African American clergymen. The suit was based on an advertisement published in the Times titled "Heed Their Rising Voices," which described actions against civil rights protesters. The advertisement contained some factual inaccuracies. Sullivan alleged that the ad defamed him in his capacity overseeing the police department, despite not being explicitly named in the advertisement.

A jury in Alabama found in favor of Sullivan and awarded him $500,000 in damages. The Alabama Supreme Court subsequently affirmed this verdict. Following this decision, the New York Times and the individual defendants appealed the case to the United States Supreme Court, challenging the lower court's ruling on First Amendment grounds.

Sullivan initiated a civil libel lawsuit in Alabama state court. A jury ruled in Sullivan's favor, awarding him $500,000 in damages. The Alabama Supreme Court subsequently affirmed this verdict. Dissatisfied with the outcome, The New York Times and the individual defendants appealed the case to the U.S. Supreme Court.

(Brennan, J.)

Yes. The Constitution protects newspapers from libel damages for publishing false statements about public officials unless there is proof of actual malice.

The First Amendment demands that debate on public issues remain uninhibited, robust, and wide-open. Erroneous statements are inevitable in free debate and must be protected to give freedom of expression the "breathing space" it needs to survive. A rule requiring critics of official conduct to guarantee the truth of all factual assertions would lead to self-censorship, dampening the vigor and limiting the variety of public debate. The constitutional safeguard is not limited to statements that are true. Even false statements must be protected to ensure freedom of expression has the "breathing space" it requires.

"Actual malice" is defined as knowledge that a statement was false or reckless disregard of whether it was false. This standard strikes the proper balance between free speech and protection of reputation for public officials. It allows criticism of government and public officials to flourish while still providing recourse for statements made with knowing or reckless falsity. The evidence in this case was constitutionally insufficient to support a finding of actual malice. Mere negligence in failing to discover misstatements is not enough. There must be convincing clarity that the defendant in fact entertained serious doubts as to the truth of the publication.

This ruling does not mean that the Constitution protects all speech about public officials regardless of its falsity. Rather, it establishes a high bar for public officials to recover damages for defamatory falsehoods relating to their official conduct. This stringent standard is necessary to ensure robust public debate and scrutiny of those in power, which is essential to democracy. The First Amendment reflects a profound national commitment to the principle that debate on public issues should be uninhibited, robust, and wide-open.

Concurrence (Black, J.) The Constitution provides an absolute, unconditional right to criticize official conduct without the threat of libel suits. This protection goes beyond the Court's 'actual malice' standard. The First Amendment fully protects freedom of speech and press against libel actions brought by public officials.

Concurrence (Goldberg, J.) The Constitution affords greater protection than the Court's 'actual malice' standard. There exists an absolute privilege to criticize official conduct. This broader interpretation better serves the First Amendment's purpose of ensuring uninhibited debate on public issues.

Concurrence (Douglas, J.) Concurred with the majority opinion without providing a separate written opinion.