Significance: In this case the Supreme Court determined that the freedom of speech and of the press can limit the award of damages to public officials who have been libeled. Thus, this decision reinforced the freedom of citizens to discuss the conduct of public officials.
Background: In 1960 a group of clergy, political activists, and performers placed an advertisement in the New York Times to raise money for the struggle for civil rights and for the legal defense of Martin Luther King Jr., who was facing a charge of perjury at that time in Montgomery, Alabama. The ad described acts of violence by the Alabama state police against students and King. The Montgomery city commissioner who supervised the police department, L. B. Sullivan, sued the New York Times and four of the African American clergy whose names appeared in the ad. He claimed that the ad libeled him because it included inaccurate statements that were made out of ill will and designed to mislead readers. Sullivan was awarded damages of $500,000 from each defendent. The New York Times appealed the case.
Decision: This case was argued on January 6, 1964, and decided on March 9, 1964, by a vote of 9 to 0. Justice William Brennan Jr. spoke for the unanimous Court, which reversed the lower court’s decision. Brennan noted that public debate should be open and unlimited, even if it resulted in sharp criticism of public figures. To require critics of public officials to be able to guarantee the truth of every statement they made would result in a restriction of free expression. Critics would be discouraged from voicing their opinions if they were unsure they could prove the truth of their statements in court. Juries, however, could award damages to public officials if the officials could prove that the statements made against them were made maliciously.
Excerpt from the Opinion of the Court: “It is of the utmost consequence that the people should discuss the character and qualifications of candidates for their suffrages [votes]. The importance to the state and to society of such discussions is so vast, and the advantages derived [received] are so great, that they more than counterbalance the inconvenience of private persons whose conduct may be involved, and occasional injury to the reputations of individuals must yield to the public welfare, although at times such injury may be great.”
