New York Times v. Sullivan

In New York Times v. Sullivan, 376 U.S. 254 (1964), the Supreme Court brought defamation into the constitutional realm. There the court held that a higher standard, actual malice, applies to actions brought by public officials against critics of their official conduct. Id. Actual malice prohibits a public official from recovering any damages for a defamatory falsehood unless he proves that the communication was made 'with knowledge that it was false or with reckless disregard of whether it was false or not.' Id. at 280. The United States Supreme Court determined that the federal constitution requires a rule prohibiting "a public official from recovering damages for a defamatory falsehood relating to his official conduct unless he proves that the statement was made with 'actual malice'--that is, with knowledge that it was false or with reckless disregard of whether it was false or not." (New York Times, supra, 376 U.S. at pp. 279-280.) The Supreme Court declared that: "The constitutional guarantees require, we think, a federal rule that prohibits a public official from recovering damages for a defamatory falsehood relating to his official conduct unless he proves that the statement was made with 'actual malice'-- that is, with knowledge that it was false or with reckless disregard of whether it was false or not." 376 U.S. at 279-80. The court "held . . . that the Constitution delimits a State's power to award damages for libel in actions brought by public officials against critics of their official conduct." 376 U.S. at 283.