St. Amant v. Thompson
390 U.S. 727 (1968)
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Rule of Law:
To establish 'reckless disregard for the truth' in a defamation action brought by a public official, the plaintiff must produce sufficient evidence to show that the defendant in fact entertained serious doubts as to the truth of the publication.
Facts:
- St. Amant, a candidate for public office, made a televised speech in Baton Rouge, Louisiana.
- During the speech, St. Amant read a transcript of questions he had asked J. D. Albin, a Teamsters Union member, and Albin's answers.
- Albin's statements concerned the allegedly corrupt activities of union president E. G. Partin and his relationship with St. Amant's political opponent.
- In one answer, Albin accused Herman A. Thompson, a deputy sheriff, of engaging in corrupt dealings with Partin, including receiving money.
- St. Amant had no personal knowledge of Thompson's activities and relied solely on Albin's sworn affidavit.
- St. Amant did not independently investigate the specific allegations made against Thompson before broadcasting them.
- St. Amant was aware that Albin was involved in a contentious internal union dispute.
Procedural Posture:
- Herman A. Thompson sued St. Amant for defamation in a Louisiana state trial court.
- The trial judge found in favor of Thompson and awarded him $5,000 in damages.
- The trial court denied St. Amant's motion for a new trial, which argued that the judgment was barred by the rule in New York Times v. Sullivan.
- St. Amant, as appellant, appealed to the Louisiana Court of Appeal.
- The Louisiana Court of Appeal reversed, holding that the record failed to show St. Amant had acted with actual malice.
- Thompson, as appellant, appealed to the Supreme Court of Louisiana.
- The Supreme Court of Louisiana reversed the intermediate appellate court's decision, finding there was sufficient evidence that St. Amant acted with reckless disregard.
- The U.S. Supreme Court granted St. Amant's petition for a writ of certiorari.
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Issue:
Does a defendant's failure to investigate the truth of a defamatory statement about a public official, without more, constitute 'reckless disregard for the truth' sufficient to prove actual malice?
Opinions:
Majority - Mr. Justice White
No. A defendant's failure to investigate the truth of a defamatory statement about a public official does not, on its own, constitute reckless disregard for the truth sufficient to prove actual malice. The Court held that the 'reckless disregard' standard requires more than a mere failure to investigate; it requires sufficient evidence to permit the conclusion that the defendant in fact entertained serious doubts as to the truth of his publication. The test is not an objective one of whether a reasonably prudent person would have published or investigated, but a subjective one concerning the defendant's actual state of mind. The Court found no evidence that St. Amant was aware of the probable falsity of Albin's statement. St. Amant's reliance on Albin's sworn affidavit, his prior verification of other information from Albin, and his knowledge that Albin was placing himself in danger by making the statements, all weighed against a finding that St. Amant entertained serious doubts about the truth of the accusations.
Dissenting - Mr. Justice Fortas
Yes. A defendant's casual, careless, and callous use of a serious libelous statement without attempting to verify its reliability constitutes reckless disregard for the truth. The dissent argued that St. Amant had a duty to check the reliability of the libelous statement before broadcasting it. The First Amendment, while protecting open criticism of public officials, should not immunize a 'character assassinator' who heedlessly makes false accusations of criminal conduct. Since St. Amant made no effort to check the facts, his actions met the standard for reckless disregard, and the judgment against him should have been affirmed.
Analysis:
This case significantly clarified the 'reckless disregard' prong of the actual malice standard established in New York Times v. Sullivan. By adopting a subjective 'serious doubts' test, the Court made it substantially more difficult for public officials to win defamation lawsuits. This decision reinforces the principle that the First Amendment protects a wide range of speech about public affairs, even some false statements, to avoid the 'chilling effect' of self-censorship. The ruling prioritizes uninhibited debate over the protection of public officials' reputations, requiring plaintiffs to prove a high level of culpability based on the defendant's actual state of mind, not merely on a failure to adhere to professional or reasonable standards of investigation.
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