ST. AMANT v. THOMPSON 390 U.S. 727 (1968) CASE BRIEF

ST. AMANT V. THOMPSON

390 U.S. 727 (1968).

NATURE OF THE CASE: A trial judge, denied a motion for a new trial and the intermediate appellate court reversed the trial court's judgment, having found that St. Amant (D) had not acted with actual malice within the meaning of the New York Times rule. The State Supreme Court reversed, finding that there had been sufficient evidence that D had acted in 'reckless disregard' in that D had no personal knowledge of Thompson's (P) activities. The Supreme Court granted certiorari.

FACTS: D, a candidate for public office, made a televised speech where he read a series of questions and answers from J. D. Albin, a member of a Teamsters Union local. The exchange concerned the allegedly nefarious activities of E. G. Partin, the president of the local, and the alleged relationship between Partin and D's political opponent. One of Albin's answers concerned Herman A. Thompson (P), an East Baton Rouge Parish deputy sheriff. Albin's statements accused P of criminal activities. P sued in defamation claiming that the publication had 'impute[d] . . . gross misconduct' and 'infer[red] conduct of the most nefarious nature.' The case was tried prior to the decision in New York Times Co. v. Sullivan. The trial judge ruled in P's favor and awarded $5,000 in damages. In the course of entertaining and denying a motion for a new trial, the Court considered the ruling in New York Times, finding that rule no barrier to the judgment already entered. The Court of Appeal reversed because the record failed to show that D had acted with actual malice, as required by New York Times. The Supreme Court of Louisiana reversed the intermediate appellate court because D recklessly disregarded whether the statements about P were true or false. The Louisiana Supreme Court ruled that D had broadcast false information about P recklessly, though not knowingly. D had no personal knowledge of D's activities; he relied solely on Albin's affidavit although the record was silent as to Albin's reputation for veracity; he failed to verify the information with those in the union office who might have known the facts; he gave no consideration to whether or not the statements defamed P and went ahead heedless of the consequences; and he mistakenly believed he had no responsibility for the broadcast because he was merely quoting Albin's words.

The Supreme Court granted a writ of certiorari.

ISSUE:

RULE OF LAW:

HOLDING AND DECISION:

LEGAL ANALYSIS:

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