Time, Inc. v. Firestone - 424 U.S. 448 (1976)
U.S. Supreme Court
Time, Inc. v. Firestone, 424 U.S. 448 (1976)
Time, Inc. v. Firestone
Argued October 14, 1975
Decided March 2, 1976
424 U.S. 448
After respondent had sought separate maintenance, her husband, the scion of a wealthy industrial family, filed a counterclaim for divorce on grounds of extreme cruelty and adultery. The court granted the counterclaim, stating that "neither party is domesticated, within the meaning of that term as used by the Supreme Court of Florida," and that "the marriage should be dissolved." On the basis of newspaper and wire service reports and information from a bureau chief and a "stringer," petitioner published in its magazine an item reporting that the divorce was granted "on grounds of extreme cruelty and adultery." After petitioner had declined to retract, respondent brought this libel action in the state court. A jury verdict for damages against petitioner was ultimately affirmed by the Florida Supreme Court. Petitioner claims that the judgment violates its rights under the First and Fourteenth Amendments.
1. The standard enunciated in New York Times Co. v. Sullivan, 376 U. S. 254, as later extended, which bars media liability for defamation of a public figure absent proof that the defamatory statements were published with knowledge of their falsity or in reckless disregard of the truth, is inapplicable to the facts of this case. Pp. 424 U. S. 452-457.
(a) Respondent was not a "public figure," since she did not occupy "[a role] of especial prominence in the affairs of society," and had not been "thrust . . . to the forefront of particular public controversies in order to influence the resolution of the issues involved." Gertz v. Robert Welch, Inc., 418 U. S. 323, 418 U. S. 345. Pp. 424 U. S. 453-455.
(b) The New York Times rule does not automatically extend to all reports of judicial proceedings regardless of whether the party plaintiff in such proceedings is a public figure who might be assumed to "have voluntarily exposed [himself] to increased risk of injury from defamatory falsehood." Gertz, supra at 418 U. S. 345. There is no substantial reason why one involved in litigation should forfeit that degree of protection afforded by the law of defamation imply by virtue of being drawn into a courtroom. Pp. 424 U. S. 455-457.
2. No finding was ever made by the divorce court that respondent was guilty of adultery as petitioner had reported, and though petitioner contends that it faithfully reproduced the precise meaning of the divorce judgment, the jury's verdict, upheld on appeal, rejected petitioner's contention that the report was accurate. Pp. 424 U. S. 457-459.
3. In a case such as this, Gertz, supra, imposes the constitutional limitations that (1) compensatory awards "be supported by competent evidence concerning the injury" and (2) liability cannot be imposed without fault. Since Florida permits damages awards in defamation actions based on elements other than injury to reputation, and there was competent evidence here to permit the jury to assess the amount of such injury, the first of these conditions was satisfied. Pp. 424 U. S. 459-461.
4. Since, however, there was no finding of fault on the part of the petitioner in its publication of the defamatory material, the second constitutional limitation imposed by Gertz was not met. Though the trial court's failure to submit the question of fault to the jury does not, of itself, establish noncompliance with the constitutional requirement, none of the Florida courts that considered this case determined that petitioner was at fault. Pp. 424 U. S. 461-464.
305 So.2d 172, vacated and remanded.
REHNQUIST, J., delivered the opinion of the Court, in which BURGER, C.J., and STEWART, BLACKMUN, and POWELL, JJ., joined. POWELL, J., filed a concurring opinion, in which STEWART, J., joined, post, p. 424 U. S. 464. BRENNAN, J., post, p. 424 U. S. 471, WHITE, J., post, p. 424 U. S. 481, and MARSHALL, J., post, p. 424 U. S. 484, filed dissenting opinions. STEVENS, J., took no part in the consideration or decision of the case.