This week I will be presenting a case study on the establishment of the need to prove actual malice in libel cases involving a public figure. In 1960, the New York Times published an ad called “Heed Their Rising Voices” in which actions of Montgomery Alabama were, in some cases inaccurately, depicted against Civil Rights protesters. L.B. Sullivan then proceeded to sue the New York Times for libel stating that by virtue of his position of superiority over the police he was identified and falsely represented in the article, though he was never specifically named. Sullivan won $500,000 in an Alabama court only to have the decision overturned by the Supreme Court with a vote of 9-0 in favor of the New York Times.
This court case demonstrated that a need for proof of actual malice in cases of libel against a public figure were necessary. At a time in which news organizations and other media outlets feared reporting on the Civil Rights movement for fear of being sued for libel, this case allowed a greater range of truth to be told. Before this decision was rendered, there was $300 million in outstanding libel actions in the southern states alone. The decision of this case has evolved into the modern requirements to prove one has fallen victim to libel, whether simple negligence proven by a private person or actual malice proven by a public figure.
I will be presenting, not only the context and content of Sullivan v. New York Times Co. (Sullivan’s original case) as well as New York Times Co. v. Sullivan, but I will also delve into the social impact of the actual malice ruling and its releasing of reporters from a passive to a more active position in reporting on the civil rights movement, I will also clarify the definitions of Libel, actual malice, simple negligence, and the five requirements to win a libel case as well as the three successful defenses against such an accusation