New York Times Co. V. Sullivan

New York Times Co. v. Sullivan

        On March 9, 1964, United States Supreme Court’s decision on the case of “New York Times Co. v. Sullivan” was a milestone for media industry; it set the standard for “Actual Malice”. It was one of the key decisions supporting the freedom of the press and gives the media a privilege when they criticize public officials. Nowadays, 40 years after the case, the law on media is still improving. The New York Times Co. v. Sullivan case was not the ending point, but it was the starting point.

        March 23rd, 1960; the New York Times received an advertisement requirement from a civil rights organization which was supporting Martin Luther King, Jr. This advertisement requirement appealed the public to support and fund Martin Luther King, Jr for his black civil rights movement. March 29th, 1960, the New York Times published a full page advertisement and the title was “Heed Their Rising Voices”. The advertisement was illuminated that southern area was suppressing the local black civil rights movement. It also criticized many police officers from Montgomery, Alabama who had encompassed a black citizen school, in order to repress the peaceful protest. The advertisement had also stated that the local police officers had arrested Martin Luther King, Jr seven times with many baseless reasons. L.B. Sullivan was the Montgomery Public Safety commissioner who was not named in the advertisement. However, the advertisement contains many inaccurate criticisms. Mr. Sullivan considered the advertisement as the defamation against him as well as his reputation. Mr. Sullivan claimed a half million dollar compensation from the New York Times. November 3rd, 1960, Mr. Sullivan won the case in an Alabama court and again in Alabama Supreme Court. The New York Time refused to obey the court decision and appealed the case to the United States Supreme Court. Eventually, the United States Supreme Court ruled for New York Times, 9-0.        

        The United States Supreme Court claimed that the law applied by the Alabama Supreme Court cannot provide the safeguards for freedom of speech and of the press that are required by the First and Fourteenth Amendments in the United States Constitution. The United States Supreme Court also claimed that under the proper safeguards the evidences presented in the case cannot significantly support Mr. Sullivan’s standing. There were three key points that supported the United States Supreme Court decision. 1, when a state court makes a decision on the civil case, it should provide a safeguard for the Fourteenth Amendments. The Fourteenth Amendments claims that “No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the Unites States” 2, Under First Amendments, freedom of speech is protected by the United States Constitution. The law is still applied even though the format of the speech had changed to paid advertisement. 3, According to the tort law when the defendant was a public figure, he or she cannot claim defamation unless the statements are made with actual malice.

        There are three important terms relating to the case and final decision, which were actual malice, public figures and malpractice. The judge believed that it was impossible for the media to make sure that all of the news are 100% accurate. The federal judges thought that even the New York Times published some untrue advertisement and also made some damage to the plaintiff regard to his reputation. Nevertheless, the plaintiff was a public figure; his must prove that there was actual malice involved or prove that the New York Times had serious malpractice. As a matter of fact, Mr. Sullivan fails to present the evidences which will prove those two conditions to support his standing. One of the issues raised in this case was does the public figure need to prove actual malice when he receive damages in a civil libel action. U.S Supreme Court emphasized that when a public figure wants to win a defamation case, he or she must unquestionably prove the actual malice or malpractice.  

        William J. Brennan, Jr. said that the value of the case was the public official’s official conduct had been criticized. It was one of the key points which the Constitution was made for. The Constitution set the limit for the government power and protects the freedom of speech. One of the issues raised in the case is the defendant liable for defamation for printing an advertisement, which criticized a public official’s official conduct. He elaborated that the freedom of speech was the key in the First Amendment. The core implication is to protect the right of public to official’s conduct without getting into the law suit. He further pointed out that the First Amendments reflects the deep faith of this nation. When the public wish to criticize the government, it should be totally free. Jr. Brennan also claimed that what advertisement had published was the social issue of this period; it should be protected by the law. The key issue was are some wrongful statements and some sort of defamations claimed by the plaintiff enough to make the advertisement lose the protection of the law. At the moment we apply the Constitution when it related to the right of free speech, it will not change regarding the statement that made by the public whether it was true or not. When public can criticize freely, however, the wrongful statement is inevitable, but we must tolerate it.

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