Monday, March 25, 2013

St. Amant v. Thompson case brief

St. Amant v. Thompson case brief
390 U.S. 727 (1968)

The case was before the Court on writ of certiorari to the Supreme Court of Louisiana filed by petitioner candidate in a defamation action filed by respondent public official. The candidate alleged that the appellate court erred in affirming an award of damages for the public official and in ruling that the candidate had recklessly broadcast false information about the public official and demonstrated actual malice.

-The public official filed a defamation action in which he alleged that the candidate had broadcast comments charging him with criminal conduct.
-The trial court ruled in the public official's favor. An intermediate appellate court reversed the judgment.
-On appeal, the state supreme court reversed and affirmed the award of damages for the public official, finding that there was ample evidence that the candidate had recklessly disregarded whether the statements made were true or false.

On certiorari, the Court reversed, holding that the state supreme court had misinterpreted and misapplied the New York Times malice standard for reckless publication.

-The record showed that the candidate had read a third party's statements about the public official during a televised speech, however, nothing referred to by the state courts indicated the candidate's awareness of the probable falsity of the statements.
-The candidate's failure to verify the information, inattention to the consequences for the public official, and mistaken belief that he had no responsibility because he was merely quoting a third party did not prove the requisite reckless disregard for the accuracy of the statements.

The plaintiff in a public official's defamation action must prove that the defamatory publication was made with "actual malice," that is, with knowledge that it was false or with reckless disregard of whether it was false or not.

OUTCOME: The Court reversed the judgment sustaining an award of damages for the public official in a defamation action against the candidate and remanded the case for further proceedings not inconsistent with the Court's opinion.

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