New York Times v. Sullivan: Summary & Overview

Instructor: Dr. Douglas Hawks

Douglas has two master's degrees (MPA & MBA) and a PhD in Higher Education Administration.

During the Civil Rights era, issues around the First Amendment rights to free speech and free press were carefully watched. In this lesson, we'll learn about New York Times v. Sullivan which was a landmark decision regarding freedom of the press.

Background of the Case

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).

The First Lawsuit: Alabama State

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.

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