Monday, April 29, 2013

Anderson v. Liberty Lobby, Inc. case brief

Anderson v. Liberty Lobby, Inc. case brief
477 U.S. 242 (1986)

CASE SYNOPSIS: Petitioners, a publisher and a magazine, sought writ of certiorari to review the decision of the United States Court of Appeals for the District of Columbia Circuit, which held that the clear and convincing evidence standard did not apply to petitioners' motion for summary judgment in a libel suit filed by respondents, a nonprofit corporation and its founder.

FACTS: Respondents filed a libel suit against petitioners following the publication of two articles portraying respondents as racists. Vacating and remanding the partial grant of petitioners' motion for summary judgment, the Court found that the court of appeals erred in holding that, for the purposes of summary judgment in a libel case, the standard of evidence required to prove actual malice was irrelevant.

Because the threshold inquiry on a motion for summary judgment revolved around whether any genuine factual issues existed which could have been resolved in favor of either party, the Court held that the determination of whether a given factual dispute required submission to a jury had to be guided by the same substantive evidentiary standards that applied to the case.

Where the libel suit involved a limited-purpose public figure, the Court held that the factual dispute involved the issue of actual malice so that the appropriate summary judgment standard required a determination of whether the evidence in record could support a reasonable jury finding that respondent had shown actual malice by clear and convincing evidence.

CONCLUSION: The Court vacated the grant of partial summary judgment in petitioners' favor and remanded the case because the incorrect standard of review was applied. A clear and convincing standard of evidence was required to determine whether actual malice existed in respondents' libel suit.

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