New York Times v. Sullivan
New York Times Company v. Sullivan, 376 U.S. 254 (1964), arose from a chief of police suing the New York Times for libel in reporting on civil rights protests. The U.S. Supreme Court ruled that a public official seeking libel damages for a matter relating to his official conduct must prove that the false statement about him had been made with actual malice that is, with conscious knowledge that the statement was false or with reckless disregard for whether it was or not. The Court held that, otherwise, the press or other critics would be restrained from speaking or writing for fear they could not readily demonstrate that what they had said was true.
During the Civil Rights Movement in the 1960s, the "Committee to Defend Martin Luther King and the Struggle for Freedom in the South" published a paid advertisement in the New York Times, describing how Chief of Police Sullivan had suppressed a civil rights demonstration in Montgomery. Sullivan sued for libel. While US law has held that true statements cannot be libelous, Sullivan argued that the advertisement contained a small error - saying that the protesters sang "My Country 'Tis of Thee" when in fact they sang "The Star-Spangled Banner" - and therefore could be libelous.
The court unanimously ruled in favor of the New York Times. Chief Justice Earl Warren wrote the opinion of the court, saying that, lest the press be restrained, even false statements must be protected by the First Amendment as long as they are not made with actual malice that is, with conscious knowledge that the statement was false or with reckless disregard for whether it was or not.
This was the first Supreme Court case to squarely address freedom of speech, so it was a groundbreaking opinion. For instance, this was the first time the Supreme Court officially said that the Sedition Act of 1798 was unconstitutional.
- Majority opinion of Chief Justice Warren
- Concurring opinion of Justice Black
- Concurring opinion of Justice Goldberg
- 376 U.S. at 279-80.