Landmark defamation cases shape the law and ethics of journalism by defining the balance between free speech and protecting reputations. These cases clarify standards like "actual malice" and distinguish between public figures and private individuals in defamation claims.
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New York Times Co. v. Sullivan (1964)
- Established the "actual malice" standard for public officials in defamation cases.
- Required proof that the publisher knew the statement was false or acted with reckless disregard for the truth.
- Strengthened First Amendment protections for the press, allowing for more robust criticism of public figures.
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Gertz v. Robert Welch, Inc. (1974)
- Clarified the distinction between public figures and private individuals in defamation cases.
- Held that private individuals do not need to prove actual malice to win a defamation suit.
- Emphasized the importance of protecting private individuals from false statements.
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Curtis Publishing Co. v. Butts (1967)
- Extended the actual malice standard to public figures, not just public officials.
- Determined that the media must exercise a high degree of care when reporting on public figures.
- Highlighted the need for responsible journalism in reporting potentially damaging information.
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Hustler Magazine v. Falwell (1988)
- Affirmed that parody and satire are protected forms of speech under the First Amendment.
- Established that public figures must prove actual malice in emotional distress claims.
- Reinforced the idea that offensive speech is still protected, as long as it does not contain false statements of fact.
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Milkovich v. Lorain Journal Co. (1990)
- Clarified that statements of opinion can be actionable if they imply false statements of fact.
- Reaffirmed the actual malice standard for public figures in defamation cases.
- Highlighted the balance between free speech and protecting reputations.
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Dun & Bradstreet, Inc. v. Greenmoss Builders, Inc. (1985)
- Addressed the issue of defamation in a private context, ruling that private individuals do not need to meet the actual malice standard.
- Emphasized the importance of protecting private individuals from false statements that could harm their business.
- Established that the First Amendment does not provide absolute protection in all defamation cases.
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Philadelphia Newspapers, Inc. v. Hepps (1986)
- Shifted the burden of proof in defamation cases involving public figures to the plaintiff.
- Required that the plaintiff prove the falsity of the statements made against them.
- Reinforced the need for a careful balance between free speech and the protection of reputations.
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Time, Inc. v. Firestone (1976)
- Determined that a private individual involved in a divorce case was not a public figure.
- Clarified the criteria for determining public figure status in defamation cases.
- Emphasized the need for a nuanced understanding of who qualifies as a public figure.
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Masson v. New Yorker Magazine, Inc. (1991)
- Addressed the issue of journalistic accuracy and the implications of altering quotes.
- Held that altering a quote could be considered defamatory if it misrepresents the speaker's views.
- Reinforced the importance of fidelity to the truth in journalism.
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Rosenbloom v. Metromedia, Inc. (1971)
- Expanded the definition of public figures to include private individuals involved in matters of public interest.
- Established that the actual malice standard applies when the subject matter is of public concern.
- Highlighted the complexities of defining public versus private figures in defamation law.