Red Lion Broadcasting Co. v. Federal Communications Commission

On 27 November 1964, Pennsylvania radio station WGCB broadcast a 15-minute program by Reverend Billy James Hargis as part of its ongoing "Christian Crusade" series. In this program Rev. Hargis discussed author Fred J. Cook's work entitled Goldwater: Extremist on the Right. Rev. Hargis disagreed with the book's positions and found fault with Cook's political beliefs and personal and work history, stating that Cook had: been dismissed from a position with the New York World Telegram newspaper for fabricating a story; had subsequently worked for a Communist-affiliated publication; and had defended alleged Communist spy Alger Hiss and attacked the Federal Bureau of Investigation and its head, J. Edgar Hoover, in his writings. Cook subsequently heard the program, determined that it constituted a personal attack against him, and demanded free air time for a reply from WGCB. The station refused Cook's request and the matter was referred to the Federal Communications Commission (FCC). The FCC ruled that Rev. Hargis's program qualified as a personal attack on Cook, and that WGCB had failed to meet its obligation as a licensed broadcaster to provide a variety of viewpoints on all subjects covered in its programming. As such, the station was ordered to provide Cook with free air time.