Knowra New York Times Co. v. Sullivan New York Times Co. v. Sullivan A 1964 U.S. Supreme Court decision holding that public officials must prove actual malice to recover damages for defamatory statements about their official conduct. It constitutionalized strong protections for criticism of government.
Actual malice : In U.S. defamation law, knowledge that a statement is false or reckless disregard for whether it is false. The Court made this state of mind necessary for public officials to win defamation damages.
Montgomery bus boycott : A 1955–1956 protest against racial segregation on Montgomery, Alabama, buses, organized by local Black residents and civil-rights leaders. The advertisement at issue solicited support for Martin Luther King Jr. during the boycott-era civil-rights struggle.
Freedom of the press in the United States : The First Amendment protection against government restrictions on publishing and journalism in the United States. Sullivan made protection from state libel judgments central to reporting on public affairs.
Alabama jury verdict against the New York Times : A $500,000 libel judgment awarded to L. B. Sullivan by an Alabama jury in 1960. The unusually large award illustrated the financial threat the Supreme Court addressed.
Public figure : A person who has attained broad fame or voluntarily entered a public controversy, subject to heightened defamation rules in relevant cases. Courts must decide which plaintiffs, beyond public officials, carry Sullivan’s actual-malice burden.
Public official : A government employee with substantial responsibility for or control over governmental affairs. The decision’s heightened proof requirement initially applied to criticism of officials’ conduct in office.
Committee to Defend Martin Luther King and the Struggle for Freedom in the South : A civil-rights group that placed a 1960 newspaper advertisement defending Martin Luther King Jr. and soliciting donations. Its advertisement in the Times contained the disputed descriptions of police conduct.
Gertz v. Robert Welch, Inc. : A 1974 U.S. Supreme Court decision setting constitutional limits on defamation liability for private individuals. Gertz distinguished private plaintiffs from public officials while retaining Sullivan’s actual-malice rule for public figures.
William J. Brennan Jr. : An associate justice of the U.S. Supreme Court from 1956 to 1990, known for influential First Amendment opinions. Brennan wrote the Court’s opinion establishing the constitutional actual-malice rule.
Actual malice in defamation law : The constitutional fault standard requiring knowledge of falsity or reckless disregard for truth in certain U.S. defamation claims. Disputes persist over how courts should apply Sullivan’s standard to journalists and other speakers.
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