Grutzmacher v. Chicago Sun-Times, Inc.

William Grutzmacher (plaintiff) was a socially and politically active business consultant who had run for Chicago mayor. Grutzmacher publicized his political and social views on talk shows and in a manuscript, speeches, fliers, and newsletters. In a column published in the editorial section of the Chicago Sun-Times (Sun-Times) (defendant), political columnist Steve Neal (defendant) compared a congressman’s tactics of stirring up ethnic prejudice to those of “Neo-Nazi Bill Grutzmacher.” Grutzmacher sued Neal and the Sun-Times for libel. After extensive discovery, Neal and the Sun-Times moved for summary judgment, arguing that being labeled a neo-Nazi was not defamatory per se, Neal’s statement was constitutionally protected opinion, and Grutzmacher failed to show actual malice. Neal presented evidence that others had characterized Grutzmacher’s speeches as anti-Semitic, white supremacist, racist, and consistent with neo-Nazi views and that Grutzmacher had denounced a watchdog organization as a phony front for the American Jewish Committee, expressed views in his manuscript comparable to those in Hitler’s Mein Kampf, was thankful his children were born in “White Man’s America,” advocated for sterilization of certain groups, was the featured speaker at a German-American celebration that distributed leaflets stating “HOLOCAUST: SIX MILLION JEW LIES,” and endorsed for alderman the American Nazi party’s national vice-chairman.