New York Times Co. V. Sullivan - Later Developments

Later Developments

  • Curtis Publishing Co. v. Butts, 388 U.S. 130 (1967) held that public figures who are not public officials may still sue news organizations if they disseminate information about them which is recklessly gathered and unchecked.
  • Gertz v. Robert Welch, Inc., 418 U.S. 323 (1974): Actual malice not necessary for defamation of private person if negligence is present
  • Westmoreland v. CBS (1982): Reaffirmed New York Times Co. v. Sullivan
  • Hustler Magazine v. Falwell, 485 U.S. 46 (1988): Extending standard to intentional infliction of emotional distress
  • Milkovich v. Lorain Journal Co., 497 U.S. 1 (1990): Existing law is sufficient to protect free speech without recognizing opinion privilege against libel claims.

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