Monday, November 11, 2013

Gertz v. Robert Welch, Inc. case brief

Gertz v. Robert Welch, Inc. case brief summary
418 U.S. 323 (1974)

CASE SYNOPSIS
Petitioner attorney challenged the decision of the United States Court of Appeals for the Seventh Circuit, which held that petitioner was a public figure and that the New York Times standard applied in his defamation action. Accordingly, the court of appeals affirmed the district court's grant of a judgment notwithstanding the verdict in favor of respondent publisher.

CASE FACTS

After a policeman killed a youth, the youth's family retained petitioner to represent them in a civil action. During the trial, respondent published an article about petitioner that labeled him as a "Communist" and a member of a Marxist organization. Because the statements contained serious inaccuracies, petitioner filed a libel action against respondent. The district court held that the New York Times standard applied, which meant that respondent escaped liability unless petitioner proved that a defamatory falsehood was published with actual malice. The district court entered judgment for respondent and the court of appeals affirmed.


DISCUSSION

  • The Supreme Court reversed and remanded, holding that petitioner was not a public figure. 
  • The state's interest in compensating injury to the reputation of a private individual required a different rule. 
  • The Court held that the states could define for themselves the appropriate standard of liability for a publisher or broadcaster of defamatory falsehood injuries to a private individual. 
  • The states could not permit recovery of presumed or punitive damages absent a showing of knowledge of falsity or reckless disregard for the truth.
CONCLUSION
The Court reversed the court of appeals' decision and held that the facts showed petitioner was a private figure. The Court held that the state interest in compensating a private figure required a different rule and held that the states could define for themselves the appropriate standard of liability for a publisher or broadcaster of defamatory falsehood injuries to a private individual. The case was remanded for a new trial.

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