HENRY
v.
COLLINS
AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.
The court held that the jury instructions allowed recovery for libel without proving the statement was made with knowledge of falsity or reckless disregard for the truth, violating the First Amendment.
Petitioner was arrested and issued a statement alleging a plot involving the County Attorney and Chief of Police. Respondents sued for libel and won j…
The full statement of facts, procedural history, and disposition for this case are member content.
Join FLexlaw to unlock all legal intelligence© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.
Explore caselaw by topic → Browse Defamatory Falsehood cases and more on FLexlaw
Per Curiam.
The petitions for certiorari are granted. The judgments are reversed.
After petitioner’s arrest on a charge of disturbing the peace, he issued a statement to the effect that this arrest was the result of “a diabolical plot,” in which respondents, the County Attorney and Chief of Police of Clarksdale, were implicated. Respondents brought suits for libel and obtained jury verdicts. The Supreme Court of Mississippi affirmed. -Miss.-, 158 So. 2d 28;-Miss. -, 158 So. 2d 695.
The following instructions requested by the respondents, approved by the trial judge, were read to the jury:
“The court instructs the jury for the plaintiff that malice does not necessarily mean hatred or ill will, but that malice may consist merely of culpable recklessness or a wilful and wanton disregard of the rights and interests of the person defamed.”
The jury, was also instructed, at respondents’ request, that
“. . . [I] f you believe from the evidence that defendant published a false statement charging that his arrest . . . was the result of a diabolical plot. . . , you may infer malice, as defined in these instructions, from the falsity and libelous nature of the statement, although malice as a legal presumption does not arise from the fact that the statement in question is false and libelous. It is for you to determine as a fact, if you have first determined from the evidence that defendant published the statement in question and that it is false, whether or not the statement in question was actually made with malice.”
The jury might well have understood these instructions to allow recovery on a showing of intent to inflict harm, rather than intent to inflict harm through falsehood. See Garrison v. Louisiana, 379 U. S. 64, 73. “The constitutional guarantees . . . [prohibit] a public official from recovering damages for a defamatory falsehood relating to his official conduct unless he proves that the statement was made . . . with knowledge that it was false or with reckless disregard of whether it was false or not.” New York Times Co. v. Sullivan, 376 U. S. 254, 279-280.
For the reasons set out in their respective concurring opinions in New York Times Co. v. Sullivan, 376 U. S. 254, 293-305, and Garrison v. Louisiana, 379 U. S. 64, 79-88, Mr. Justice Black, Mr. Justice Douglas and Mr. Justice Goldberg concur in reversal of these judgments, not merely for error in the instructions read to the jury, but on the ground that it would violate the First and Fourteenth Amendments to subject petitioner to any libel judgment solely because of his publication of criticisms against respondents’ performance of their public duties.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By (24 total)
-
Palm Beach Newspapers, Inc. v. Early, 334 So. 2d 50 (Fla. 4th DCA 1976)…ew York Times standard relating to a public official — knowledge of falsity or reckless disregard of the truth. See, Beckley Newspapers Corp. v. Hanks, 389 U.S. 81, 88 S.Ct. 197, 19 L.Ed.2d 248 (1967); Garrison v. Louisiana, supra; Henry v. Collins, 380 U.S. 356, 85 S.Ct. 992, 13 L.Ed.2d 892 (1965); Rosenblatt v. Baer, 383 U.S. 75, 84, 86 S.Ct. 669, 15 L.Ed.2d 597 (1966); Greenbelt Cooperative Publishing Ass’n, Inc. v. Bresler, 398 U.S. 6, 9-11, 90 S.Ct. 1537, 26 L.Ed.2d 6 (1970). Additionally, it has been…
-
Finkel v. Sun-Tattler Co., Inc., 44 Fla. Supp. 13 (Broward Cty. Cir. Ct. 1976)…matter of law that the following did not meet the “constitutional malice” standard— falsity, defamatory content, failure to retract and investigatory failure in New York Times; ill will and negligence in Garrison, supra, and Henry v. Collins (1965) 380 U.S. 356 (the latter without even requiring oral argument); falsity in Butts, supra; failure to investigate in Beckley v. Hanks (1967) 389 U.S. 81 (again without oral argument) and Butts; defamatory content in Greenbelt v. Bresler (1970) 398 U.S. 6; and mist…
-
OLD Dominion Branch NO. 496, Nat'l Ass'n OF Letter Carriers, AFL-CIO v. Austin, 418 U.S. 264 (U.S. 1974)…iff, or bad motives, are not elements of the New York Times standard.” Rosenbloom v. Metromedia, Inc., 403 U. S. 29, 52 n. 18 (1971) (opinion of Brennan, J.). Accord, Garrison [*282] v. Louisiana, 379 U. S. 64, 73-74, 77-79 (1964); Henry v. Collins, 380 U. S. 356 (1965); Rosenblatt v. Baer, 383 U. S. 75, 84 (1966); Greenbelt Cooperative Publishing Assn. v. Bresler, 398 U. S. 6, 9-11 (1970). It is therefore clear that the libel judgments in this case must be reversed because of the court’s erroneous instructi…
Previewing 3 of 24 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- N.Y. Times Co. v. Sullivan, 376 U.S. 254 (U.S. 1964)
- Garrison v. Louisiana, 379 U.S. 64 (U.S. 1964)