Patrick v. Field Research Corp. Et Al.

1973-10-15

Headline: Court refuses to review a $300,000 libel verdict over campaign accusations, leaving the award against a candidate and a polling firm in place while the dispute remains unresolved.

Holding: The Court denied review, leaving a $300,000 libel judgment against the candidate who accused a polling firm of rigging a campaign poll in place.

Real World Impact:

Leaves a $300,000 libel award against the candidate and pollster intact.
Permits libel damages after heated campaign accusations to stand absent Supreme Court review.
Dissent argues First Amendment should bar libel damages for public affairs speech.

Topics: libel and defamation, campaign speech, freedom of speech, political polling

Summary

Background

A political candidate challenged a published poll showing he had only 1% support in a Republican primary. He publicly accused the poll of being corrupt, dishonest, and rigged because of a bribe allegedly paid by another candidate. The polling firm sued for libel and recovered $300,000 in damages; the parties agreed the candidate was a public figure, so the award turned on whether the candidate acted with "malice."

Reasoning

The Supreme Court denied the candidate’s request to review the case, leaving the lower-court judgment intact. The opinion of the Court is simply the denial of review; no majority opinion explaining the merits appears in the text provided. In a written dissent, Justice Douglas argued that the First Amendment bars using civil libel laws to impose damages for discussion of public affairs and that proving a speaker’s "malice" provides only weak protection for free speech.

Real world impact

Because the Court refused to hear the case, the $300,000 libel award remains enforceable as described in the lower-court judgment. The outcome affects the candidate and the polling firm and leaves unresolved the broader constitutional question Justice Douglas raised about whether libel damages should ever apply to speech about public affairs. The ruling is not a final Supreme Court decision on the constitutional issue and could be revisited in a future case.

Dissents or concurrances

Justice Douglas dissented from the denial and would have granted review and reversed, urging that the First Amendment should categorically protect discussion of public affairs from civil libel damages.