Douglas has two master's degrees (MPA & MBA) and a PhD in Higher Education Administration.
At a time when civil rights and segregation were very controversial topics in the United States, a group that supported Martin Luther King, Jr. took out a full-page advertisement in the New York Times. This ad not only requested donations to help defend King against perjury charges, but also accused the Montgomery Police Department of abuse of civil rights protestors. These accusations in the advertisement contained some minor inaccuracies to include stating that King had been arrested seven times when in actuality he had only been arrested four times and stating that some protestors sang one song while staging a demonstration, when they actually sang another.
While the ad didn't mention L.B. Sullivan, who was an elected Commissioner of the City and responsible for the police department, by name, he felt that because the ad said negative things about the Montgomery Police department, it qualified as libel, a written, false statement that causes harm to someone's reputation, against him, especially since some of the information in the ad was clearly erroneous (regardless that these erroneous statements were 'unimportant' details).
Sullivan sued the New York Times for libel in the circuit court of Montgomery County. He won that case and was awarded $500,000 in punitive damages, damages awarded to punish the defendant. Under appeal, the Supreme Court of Alabama confirmed the decision. This was a real source of concern for newspapers and media agencies around the country, because it put the burden of proof for libel so low for the plaintiff that the freedom of the press was severely limited. Because it was such an important case, the New York Times appealed the case to the Supreme Court.
In a separate case, Abernathy v. Sullivan, Sullivan was also suing over the same ad, but instead of the New York Times he was suing four of the African American preachers who had helped finance the ad, one of whom was Abernathy. Sullivan won this case at the state level, as well; however, it was also appealed to the Supreme Court and heard along with the New York Times v. Sullivan case.
The Supreme Court case of New York Times Company v. Sullivan (and Abernathy v. Sullivan) was argued on January 6-7, 1964, and decided on March 9 of that same year. In a 9-0 decision, the Court voted in favor of the New York Times Company, negating the ruling of the Alabama Supreme Court. The Supreme Court held that public officials not only have the burden of proof in a libel case, but that they must also prove actual malice, meaning that the press had to publish something that it knew was false and/or had to publish something with 'reckless disregard for the truth.' With this burden of proof, Sullivan's case collapsed.
While it may seem that the Supreme Court's decision was just a reversal of the lower court's decision, New York Times v. Sullivan was a landmark case in that, for the first time, the court applied the actual malice standard in a First Amendment freedom of the press case.
New York Times v. Sullivan, decided in 1964, is an oft-cited Supreme Court case that had important implications for the freedom of the press. Instead of general inaccuracies and vague references to public officials being sufficient for a successful libel suit, the Supreme Court required that actual malice must be proven by the plaintiff.
This case repositioned the press from needing to be very careful and conservative about what they published to being able to include quotes from sources that may not be read as favorable on public officials. This then allowed the public to ask more questions and ultimately hold public officials accountable for their actions.
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MTEL Speech (44): Practice & Study Guide14 chapters | 133 lessons | 12 flashcard sets
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