New York Times V Sullivan The New York Times Test

The New York Times Co. v. Sullivan
376 U.S. 254 (1964)
Date: March 9, 1964
Court: Supreme Court of the United States
The New York Times ran a full-page ad that claimed Rev. Martin Luther King Jr.’s arrest was part of campaign to destroy his efforts to integrate public facilities and encourage blacks to vote. Montgomery city commissioner L.B. Sullivan filed a libel action against the newspaper. He claimed the false allegations against Montgomery police defamed him as well.
The case was first held in the Alabama Supreme Court. Sullivan sent a request for retraction of the advertisement and when the newspaper refused, Sullivan won a $500,000 judgment.
The case made it to the U.S. Supreme Court and was argued in 1964. In a 9-0-majority ruling, the Court remanded the case sustaining the First Amendment case.
This case established the actual malice standard, which rules that public officials need to prove actual malice in order to recover damages for libel. Actual malice is defined as “the publications of defamatory material with the knowledge that is was false or reckless disregard of whether it was false or not.
New York Times v. Sullivan was a landmark case in the support of freedom of the press.

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