St. Amant v. Thompson
United States Supreme Court
390 U.S. 727 (1968)
St. Amant (defendant) made a televised speech in which he falsely accused Thompson (plaintiff), a deputy sheriff and thus public official, of criminal conduct. Thompson brought suit for defamation. The trial judge found in favor of Thompson and denied St. Amant’s motion for a new trial based on the holding in New York Times v. Sullivan, 376 U.S. 254 (1964), which was decided after the trial. The appellate court reversed the judgment, finding that St. Amant had not acted with actual malice as defined in Sullivan. The Louisiana Supreme Court reversed, finding that St. Amant had made the statement recklessly, although not knowingly, and had thus acted with actual malice. The United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (White, J.)
Concurrence (Black, J.)
Dissent (Fortas, J.)
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