This essay analyzes two cases before the Supreme Court, New York Times v. Sullivan, 376 U.S. 254 (1964), and Toyota Motor Manufacturing, Kentucky, Inc. v. Williams, Case No. 00-1089 decided January 8, 2002.
Parties. L. B. Sullivan, an elected Commissioner of the City of Montgomery, Alabama, who was responsible for its police, sued the New York Times and four black clergymen in Alabama state court.
Issues and Their Relationship to the Parties. The lawsuit alleged that an advertisement which appeared in the Times on March 29, 1960 and which contained a number of statements critical of the City of Montgomery, including the remark that a civil rights demonstration there had been met with "unprecedented wave of terror," constituted a civil libel of Sullivan by the four named defendants and the Times under Alabama law. The advertisement was sponsored by 64 civil rights leaders, including the four individual defendants. An Alabama jury found the defendants liable and awarded Sullivan $500,000 in general and punitive damages. The jury verdict was affirmed by the Alabama Supreme Court. The issue before the United States Supreme Court was whether this application of Alabama's libel laws violated the free speech provisions of the First Amendment to the Constitution.
Holding. The Court held unanimously that the Alabama jury verdict and its affirmation by the Alabama Court violated the free speech rights of defendants which were protected by the First Amendment.
Reasoning of the Court. The First Amendment provides inter alia that "Congress shall make no law . . . abridging the freedom of speech or of the press." Section 1 of the Fourteenth Amendment provides that no State "shall . . . deprive any person of life, liberty, or property, without due process of law."
Preliminary determinations. Sullivan's counsel argued that no action by Congress was involved and therefore the First Amendment did not apply. Justice William Brennan...