Saturday, December 7, 2013

Hutchinson v. Proxmire case brief

Hutchinson v. Proxmire case brief summary
443 U.S. 111 (1979)


CASE SYNOPSIS
Plaintiff research scientist appealed the grant of summary judgment for defendants, a senator and his assistant, from the United States Court of Appeals for the Seventh Circuit, in an action for libel, intentional infliction of emotional distress, interference with contractual relations, and infringement of plaintiff's rights of privacy, peace, and tranquility.

CASE FACTS
Plaintiff was a research behavioral scientist who studied emotional behavior in monkeys. Most of his research was funded by government grants. Respondents were a United States Senator and his legislative assistant. Respondent senator awarded plaintiff the Golden Fleece Award for presenting an egregious example of wasteful governmental spending. Respondents publicized the award through telephone calls, radio and television interviews, and newsletters. Plaintiff filed his action for libel, intentional infliction of emotional distress, interference with contractual relations, and infringement of his rights to privacy, peace, and tranquility.

DISCUSSION
  • Reversing the district court and the appeals court, the United States Supreme Court held that plaintiff was not a "public figure," and therefore the "actual malice" standard did not apply to him. 
  • In addition, the Court held that the Speech and Debate Clause of the United States Constitution did not protect respondents for defamatory statements they made or might make. 
  • That meant that the libelous remarks made by respondents in followup telephone calls to executive agencies, and in the television and radio interview, were not protected.
CONCLUSION
The Court reversed the grant of summary judgment and remanded the matter for further proceedings.

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