St. Amant v. Thompson

Background

In June 1962 a political candidate, St. Amant, made a televised speech reading answers from a union member, Albin, that accused a union leader of wrongdoing and mentioned Herman Thompson, an East Baton Rouge deputy sheriff. Thompson sued for defamation, alleging the broadcast falsely charged him with criminal conduct. A trial judge awarded $5,000 before the New York Times v. Sullivan rule. The Louisiana courts split on whether St. Amant acted with the "actual malice" the Constitution requires for public officials, and the Supreme Court took the case to resolve that question.

Reasoning

The Court asked whether the state court correctly applied the New York Times standard that a public official must prove the speaker knew a statement was false or recklessly disregarded its probable falsity. The Court accepted that the statement was false and Thompson was a public official, but found the record lacked proof that St. Amant actually entertained serious doubts about its truth. Mere failure to investigate, reliance on an informant's affidavit, or being "heedless" of consequences did not prove reckless disregard. The Court noted Albin had sworn to his answers, St. Amant had known him months earlier, and St. Amant had verified other details; thus the judgment for Thompson could not stand.

Real world impact

This ruling raises the proof needed for public officials to win defamation suits, protecting speakers who publish third‑party allegations absent clear evidence the speaker doubted them. The case reverses the state judgment and sends the record back for further proceedings consistent with the Court's standards.

Dissents or concurrances

Justice Fortas dissented, arguing the broadcaster showed careless recklessness and should lose; Justices Black and Douglas joined the judgment in line with earlier concurrences.