Garrison V Louisiana The Garrison Test

Factual Background
The Plaintiff, Jim Garrison serves as a district attorney of Orleans Parish, LA.
Jim Garrison, at a press conference made statements against the Judges of the Criminal District Court of the Orleans Parish regarding their lack of good judicial conduct on the job.
The aforementioned judges brought suit against Mr. Garrison, alleging these statements violated the Louisiana Criminal Defamation Statute, which “punishes false statements without regard to that test if made with ill-will; even if ill-will is not established, a false statement concerning public officials can be punished if not made in the reasonable belief of its truth”.
The case centers on those accusations of Mr. Garrison in which he claimed the judges to be inefficient, lazy, taking too much vacation time and allowing pending criminal cases to pile up.
He also stated that they refused on several occasions to approve funding for undercover investigations he felt his office needed to do their job.

Procedural History
Upon charged with violation of the Louisiana Criminal Defamation Statute, the appellant was tried without a jury before a judge from another parish and convicted.
Mr. Garrison appealed this decision to The Supreme Court of Louisiana, which agreed to hear the case, 244 La. 787, 154 So.2d 400.
“The trial court and the State Supreme Court both rejected appellant's contention that the statute unconstitutionally abridged his freedom of expression.”
The appellant was granted certiorari by the U.S. Supreme Court, which agreed to hear his case.
The decisions of the District Court and Supreme Court of Louisiana were reversed by the U.S. Supreme Court and Mr. Garrison’s conviction was overturned.

Can the New York Times v. Sullivan actual malice rule be aptly applied to this case?
Is the Louisiana Criminal Defense Statue Mr. Garrison was charged of violating constitutionally valid or in violation of his freedom of expression?

All lower court decisions reversed and conviction of the appellant dropped.

“The New York Times rule also limits state power to impose criminal sanctions for criticism of the official conduct of public officials.”
“The Louisiana statute, as authoritatively interpreted by the Supreme Court of Louisiana, incorporates constitutionally invalid standards in the context of criticism of the official conduct of public officials.”
“Proof of actual malice is relevant to seditious libel — that seditious libel will lie for a knowingly false statement, or one made with reckless disregard of the truth.”

The reasoning of the lower courts was based on actual malice intended by the Plaintiff, but the U.S. Supreme Court holds that these decisions were not based on constitutionally valid principles, and improper applications of the New York Times actual malice rule.

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