Garrison v. Louisiana

Jim Garrison (defendant) was the district attorney for Orleans Parish, Louisiana (the parish). Garrison was involved in a dispute with eight judges of the parish’s criminal court. Garrison held a press conference in which he stated that the parish’s large backlog of pending criminal cases could be attributed to the judges’ inefficiency, laziness, and excessive vacation time. Garrison also suggested that the judges had thwarted Garrison’s law-enforcement efforts by not authorizing money to be used to cover investigators’ expenses. Garrison questioned whether the judges had been improperly influenced by people who did not want the laws to be enforced. The State of Louisiana (plaintiff) charged Garrison with violating Louisiana’s Criminal Defamation Statute (the statute). The statute punished true statements made with ill will, enmity, or a wanton desire to injure. The statute also punished false statements if made with ill will or without a reasonable belief in the statements’ truth. Garrison was convicted following a bench trial in which the trial court found that Garrison had made false statements about the judges with ill will and without reasonable belief in the statements’ truth. Garrison appealed, arguing that the statute unconstitutionally interfered with his freedom of expression. The Louisiana Supreme Court affirmed the conviction, and Garrison appealed to the United States Supreme Court.