St. Amant v. Thompson, 390 U.S. 727 (1968)
The reckless disregard for truth element in defamation claims requires a plaintiff to show that the defendant had serious doubts about the accuracy of the material.
During a televised speech, St. Amant read statements by Albin that accused Thompson of criminal conduct. There was no basis for the allegations, and Thompson sued St. Amant for defamation. Although the trial court awarded damages, the intermediate appellate court disallowed the damages award on the theory that Thompson had not met the standard of actual malice required for these claims under the U.S. Supreme Court decision in New York Times v. Sullivan (1964).
The state supreme court then reversed, finding that reckless disregard for the truth was sufficient grounds to find the defendant liable and that Thompson had met this standard because St. Amant had failed to verify the allegations before repeating them.
- Byron Raymond White (Author)
- Earl Warren
- John Marshall Harlan II
- William Joseph Brennan, Jr.
- Potter Stewart
- Thurgood Marshall
Recklessness requires a higher level of proof than ordinary negligence, so the reasonable-care standard is not appropriate. The defendant cannot avoid liability by testifying that he had a subjective belief that the statements were true. Instead, the jury must find through its consideration of all of the relevant evidence that the statements had been made in good faith. There was no evidence in this situation that St. Amant had entertained serious doubts about the veracity of Albin's accusations. The absence of an effort to check their facts did not rise to the level of actionable conduct.
- Hugo Lafayette Black (Author)
- William Orville Douglas
- Abe Fortas (Author)
This decision clarified the requirement of malice in defamation lawsuits regarding matters of public concern. It does not mean ill will but rather knowledge of the information's falsity or reckless disregard of the truth.
U.S. Supreme CourtSt. Amant v. Thompson, 390 U.S. 727 (1968)
St. Amant v. Thompson
Argued April 4, 1968
Decided April 29, 1968
390 U.S. 727
Petitioner made a televised political speech in the course of which he read questions which he had put to a union member, Albin, and Albin's answers; the answers falsely charged respondent, a public official, with criminal conduct. Respondent sued petitioner for defamation, and was awarded damages by the trial judge. The trial judge, having considered New York Times Co. v. Sullivan, 376 U. S. 254 (1964), decided after the trial, denied a motion for a new trial. An intermediate appellate court reversed the trial court's judgment, having found that petitioner had not acted with actual malice within the meaning of the New York Times rule, i.e., with knowledge that petitioner's statements were false or with reckless disregard of whether they were false or not. The State Supreme Court reversed, finding that there had been sufficient evidence that petitioner had acted in "reckless disregard" in that petitioner had no personal knowledge of respondent's activities; relied solely on Albin's affidavit though there was no evidence as to Albin's veracity; failed to verify the information with others who might know the facts; did not consider whether the statements were defamatory, and mistakenly believed that he had no responsibility for the broadcast because he was merely quoting Albin.
Held: In order that it can be found that a defendant, within the meaning of New York Times, acted in "reckless disregard" of whether a defamatory statement which he made about a public official is false or not, there must be sufficient evidence to permit the conclusion that the defendant had serious doubts as to the truth of his publication. Pp. 390 U. S. 730-733.
(a) In a defamation action by a public official, reckless conduct is not measured by whether a reasonably prudent man would have published the statement or would have investigated before publishing. P. 390 U. S. 731.
(b) The people's stake in the conduct of public officials is so great that neither the defense of truth nor the standard of ordinary care would adequately implement First Amendment policies. Pp. 390 U. S. 731-732.
(c) A defendant's testimony that he acted in good faith is not conclusive as to that issue, since the factfinder, in the light of all
the surrounding circumstances. must determine whether the publication was indeed made in good faith. P. 390 U. S. 732.
(d) The evidence in this case is not sufficient to permit the conclusion that petitioner acted in reckless disregard of whether the statements about respondent were false or not. Pp. 390 U. S. 732-73. .
250 La. 405, 196 So. 2d 255, reversed and remanded.