New York Times v. Sullivan

The U.S. Supreme Court limited for the first time states' authority to award libel damages based on individual state laws and defined "actual malice" as a national standard for determining libel cases involving public figures.

On 23 March 1960 an organization calling itself the "Committee to Defend Martin Luther King and the Struggle for Freedom in the South" paid the New York Times to publish a certain advertisement. The ad took up one full page and was a call for public support and money to defend Reverend Martin Luther King, Jr. and the civil rights struggle in the South. Bearing the caption "Heed Their Rising Voices" in large, bold print, the ad was published in the 29 March 1960 edition of the Times.

The ad criticized several Southern jurisdictions, including the city of Montgomery, Alabama, for breaking up various civil rights demonstrations. No individual was mentioned by name. Further, the ad declared that "Southern violators of the Constitution" were determined to destroy King and his movement. The reference was to the entire South, not just Montgomery and other localities, and again no individual was mentioned by name.

Over 600,000 copies of the 29 March 1960 Times edition carrying the ad were printed. Only a couple hundred went to Alabama subscribers. Montgomery City Commissioner L.B. Sullivan learned of the ad through an editorial in a local newspaper. Incensed, on 19 April 1960 Sullivan sued the Times for libel in the Circuit Court of Montgomery County, Alabama. Sullivan claimed that the ad's reference to Montgomery and to "Southern violators of the Constitution" had the effect of defaming him, and he demanded $500,000 in compensation.

On 3 November 1960 the circuit court found the Times guilty and awarded Sullivan the full $500,000 in damages. The Alabama Supreme Court affirmed the circuit court judgment on 30 August 1962. In its opinion, the Alabama Supreme Court gave an extremely broad definition of libel:

Where the words published tend to injure a person libeled by them in his reputation, profession, trade or business, or charge him with an indictable offense, or tends to bring the individual into public contempt [they] are libelous per se . . . We hold that the matter complained of [by Sullivan] is, under the above doctrine, libelous per se.