Torts II, Pages 931–933

St. Amant v. Thompson

Supreme Court of the United States, 1968

Facts:

Defendant had asked a union member some questions and then read parts of their questions and answers in a televised speech. The union member's answers falsely charged plaintiff, a deputy sheriff, with criminal conduct.

Procedural History:

  • Trial court awarded plaintiff damages.

  • Appellate court reversed, finding that defendant had not acted with actual malice in accordance with the New York Times rule.

  • Louisiana Supreme Court reversed, finding that defendant acted in "reckless disregard" of the truth because he did not verify the facts he repeated and did not consider whether the words were defamatory.

Takeaway Rule/Holding:

For a false publication to be made with reckless disregard, there must be evidence defendant entertained serious doubts as to the truth of the publication or with a high degree of awareness of probable falsity.

Issue:

What is "reckless disregard?"

Judgment:

Reversed and remanded.

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