Curtis Publishing Co. v. Butts case brief summary
388 U.S. 130 (1967)
CASE FACTS
The Court reviewed two cases to consider the impact of its decision that the constitutional guarantees of freedom of speech and press required a federal rule that prohibited a public official from recovering damages for a defamatory falsehood relating to his official conduct unless he proved that the statement was made with "actual malice" on libel actions instituted by persons who were not public officials, but were "public figures" involved in issues in which the public had an important interest.
DISCUSSION
The Court affirmed the judgment in favor of appellee in the first libel case because ample evidence supported a finding of highly unreasonable conduct constituting an extreme departure from the standards of investigation and reporting ordinarily adhered to by responsible publishers and reversed the judgment for appellee in the second case as there was no indication of a severe departure from the accepted standards.
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388 U.S. 130 (1967)
CASE SYNOPSIS
Appellant publishers, in
separate and unrelated actions, sought review of judgments from the
United States Court of Appeals for the Fifth Circuit and the Court of
Civil Appeals of Texas, respectively, in favor of appellee
individuals in appellees' libel actions in light of a subsequent
decision of the Court that prohibited a public official from
recovering damages for defamatory falsehoods relating to his official
conduct absent actual malice.CASE FACTS
The Court reviewed two cases to consider the impact of its decision that the constitutional guarantees of freedom of speech and press required a federal rule that prohibited a public official from recovering damages for a defamatory falsehood relating to his official conduct unless he proved that the statement was made with "actual malice" on libel actions instituted by persons who were not public officials, but were "public figures" involved in issues in which the public had an important interest.
DISCUSSION
- The Court concluded that these libel actions could not be left entirely to state libel laws, unlimited by any overriding constitutional safeguard, but that the rigorous requirements of the Court's decision regarding public officials was not the only appropriate accommodation of the conflicting interests at stake.
- The Court held that a "public figure" who was not a public official could also recover damages for a defamatory falsehood, whose substance made substantial danger to reputation apparent, on a showing of highly unreasonable conduct that constituted an extreme departure from the standards of investigation and reporting ordinarily adhered to by responsible publishers.
The Court affirmed the judgment in favor of appellee in the first libel case because ample evidence supported a finding of highly unreasonable conduct constituting an extreme departure from the standards of investigation and reporting ordinarily adhered to by responsible publishers and reversed the judgment for appellee in the second case as there was no indication of a severe departure from the accepted standards.
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