New York Times v. Sullivan

The Court held that public officials cannot recover for defamation absent actual malice, transforming First Amendment law.

Overview

An Alabama official won five hundred thousand dollars over minor inaccuracies in a civil rights fundraising advertisement. Justice Brennan, for the majority, held that debate on public issues should be uninhibited, robust, and wide-open, and that erroneous statements are inevitable in free debate. Public officials must prove the statement was made with knowledge of falsity or reckless disregard for the truth. The actual malice standard, later extended to public figures, protected news media from crushing state libel verdicts and enabled national reporting on the civil rights movement. Sullivan remains the anchor of American defamation law.