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Palin v. The New York Times Co.

United States District Court for the Southern District of New York
264 F. Supp. 3d 527 (S.D.N.Y. 2017)


In 2011, Jared Loughner shot Gabby Giffords and killed six others. In weeks beforehand, Sarah Palin’s (plaintiff’s) political action committee (SarahPAC) circulated a map of districts Republicans had targeted with crosshairs over them and pictures below of incumbent Democrats, including Giffords. The media speculated about a connection but never confirmed one. When James Hodgkinson opened fire at a congressional baseball game in 2017, New York Times Company (defendant) editor James Bennet had a writer review the Loughlin articles, then write an editorial about the Hodgkinson shooting. The editorial included a link to an ABC news article finding no connection. Bennet rewrote the piece stating a “clear” connection between Loughner’s attack and the map, incorrectly described as placing crosshairs over incumbents themselves, and referring to “direct” political incitement. Bennet retained the ABC news article link without reading it. The Times revised the piece and ran corrections the next day. Palin nonetheless sued for libel. The Times moved to dismiss, arguing Palin’s complaint did not state the elements required for a public figure to recover for libel. Bennet testified that he did not remember the Loughner articles when he rewrote the Hodgkinson piece. After hearing, the court issued its opinion.

Rule of Law


Holding and Reasoning (Rakoff, J.)

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