Case Brief: St. Amant v. Thompson, 390 U.S. 727

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St. Amant v. Thompson, 390 U.S. 727

United States Supreme Court

1968

Chapter	17	Title	Defamation
Page	741	Topic	Application of the Actual Malice Standard
Quick Notes	St. Amant in a televised political speech, read statements falsely charging Thompson, a deputy sheriff, with criminal conduct relating to a union dispute.
Book Name	Torts Cases, Problems, And Exercises. Weaver, Third Edition. ISBN: 978-1-4224-7220-0.

Issue

o Whether defamation of a public official demonstrates a reckless disregard for truth or falsity if done without investigation? No, you must prove the Df had serious doubts about the truth of falsity.

Procedure
Trial	o The trial judge ruled in Thompson's favor and awarded $5,000 in damages
Appellant	o Reversed - Because the record failed to show that St. Amant had acted with actual malice
Louisiana	o Reversed - There was sufficient evidence that St. Amant acted with reckless disregard regarding whether the statements about Thompson were true or false
US	o Reversed and Remanded The State court misunderstood and misapplied the actual malice standard which must be observed in a public official's defamation action

Facts

Reason

Rules

o Pl - Thompson

o Df - St. Amant

What happened?

o St. Amant (Df), a candidate for public office, made a televised political speech, during which he read statements made by Albin, a union member, falsely charging Thompson (Pl), a deputy sheriff, with criminal conduct.

Alleged Defamation

o "Now, we knew that this safe was gonna be moved that night, but imagine our predicament, knowing of Ed's connections with the Sheriff's office through Herman Thompson.

o We also knew of money that had passed hands between Ed and Herman Thompson . . . from Ed to Herman.

o We also knew of his connections with State Trooper Lieutenant Joe Green.

o We knew we couldn't get any help from there and we didn't know how far that he was involved in the Sheriff's office

Thompson Brought Suit

o Claiming the publication had "impute[d] . . . gross misconduct" and "infer[red] conduct of the most nefarious nature."

Trial Court For Thompson

o The trial judge ruled in Thompson's favor and awarded $5,000 in damages.

o Pl - Public Official.

o Df - Public Official.

o Controversy Public.

Louisiana Court of Appeal reversed

o Because the record failed to show that St. Amant had acted with actual malice

Supreme. Ct of Louisiana reversed

o There was sufficient evidence that St. Amant recklessly disregarded whether the statements about Thompson were true or false.

Defamation

o In a defamation suit, a public official must prove the Df had serious doubts as to the truth of his publication in order to demonstrate actual malice.

Reckless Conduct Analysis

o Reckless conduct is not measured by whether a reasonably prudent man would have published, or would have investigated before publishing.

o There must be sufficient evidence to permit the conclusion that the defendant in fact entertained serious doubts as to the truth of his publication.

o Publishing with such doubts shows reckless disregard for truth or falsity and demonstrates actual malice.

Public Policy Concerns

o It is essential that the First Amendment protect some erroneous publications as well as true ones.

o False information helps the truth get out.

Who determines if Statements were made in Good Faith?

o The finder of fact must determine whether the publication was indeed made in good faith.

o The Df - cannot automatically insure a favorable verdict by testifying that he believed the statements were true.

Non-Persuasive Professions of Good Faith Examples (Finding Recklessness)

1. Unverified anonymous telephone call.

2. When the publisher's allegations are so inherently improbable that only a reckless man would have put them in circulation.

3. Recklessness may be found where there are obvious reasons to doubt the veracity of the informant or the accuracy of his reports.

Supreme Court Reasoning J. White

o By no proper test of reckless disregard was St. Amant's broadcast a reckless publication about a public officer.

o Nothing referred to by the Louisiana courts indicates an awareness by St. Amant of the probable falsity of Albin's statement about Thompson.

o Failure to investigate does not establish bad faith.

o Mistake about his probable legal liability does not evidence a doubtful mind on his part.

o Most state courts could say was that there was no evidence in the record of Albin's reputation for veracity.

o St. Amant testified that he had verified other aspects of Albins information and that he had affidavits from others.

o St. Amant placed himself in personal danger.

Holding

o Because the state court misunderstood and misapplied the actual malice standard which must be observed in a public official's defamation action, the judgment is reversed and the case remanded for further proceedings not inconsistent with this opinion.

Reversed and remanded.

DISSENT - Fortas

o Petitioner had a duty to check the reliability of the libelous statement about Thompson.

o If he had made a good-faith check, then he should be protected.

o The First Amendment is not a shelter for the character assassinator.

o Being a public officeholder does not forfeit ones membership in the human race.

Class Notes

St. Amant in a televised political speech, read statements falsely charging Thompson, a deputy sheriff, with criminal conduct relating to a union dispute