The Supreme Court redefined freedom of the press by requiring that someone wishing to recover damages from a newspaper for a false story had to show that the newspaper had actual malice or a reckless disregard for the truth.
The New York Times printed an advertisement appealing for funds for civil rights organizations that included technically false statements about Montgomery, Alabama, police commissioner Sullivan. The Supreme Court was asked to rule on a half-million dollar civil damage award to the Sullivan. There was no showing that the Times had any actual malice or reckless disregard for the truth in printing the statements. The most that could be alleged was that the Times was negligent.
The Court’s unanimous decision in favor of the newspaper gave vastly greater protection to the news media from libel suits resulting from the publication of factual errors. In his opinion for the Court, Justice William J. Brennan, Jr.,
As a result, it became extraordinarily difficult for public officials to ever win a damage suit against a newspaper or television station, no matter how false or defamatory the statements against them were. The same situation also confronts those people who are defined as “public figures.” A public figure, for purposes of defamation law, is a person who “thrusts himself into a public controversy in order to affect its outcome.” An otherwise little-known person unwillingly caught up in a matter of public interest is not a public official and thus need prove only negligence (not actual malice) to prevail against a defamer, according to Wolston v. Reader’s Digest Association
Garrison v. Louisiana
Gertz v. Robert Welch
Milkovich v. Lorain Journal Co.
Time v. Hill