Rule of Law
Public personalities and officials cannot sue for deliberate infliction of emotional distress caused by publications unless they can establish “actual malice” in the publication. This means the speaker lied or was wilfully oblivious to the truth.
Facts of the Case
Jerry Falwell (plaintiff) was a clergyman who often gave his opinion on current events on national television. Larry Flynt’s Hustler magazine (defendants) was a nationwide sensation for its racy and sometimes explicit sexual content. In one issue of Hustler, Falwell’s purported “first time” was mocked in a spoof advertising for a liqueur. Falwell’s mother and a portable toilet had a role in the specifics. The advertisement was satirical since it included a disclaimer at the page footer. Falwell filed a lawsuit against Hustler for libel, invasion of privacy, and intentional infliction of emotional distress in a United States district court as part of a diversity action. When considering the libel issue, the jury sided with Falwell, concluding that the satirical advertisement could not have been taken seriously as expressing facts about Falwell.
The jury awarded Falwell $200,000 in damages but ruled in his favor on the intentional infliction of mental anguish allegation. The Fourth U.S. Circuit Court of Appeals upheld the lower court’s decision. The Fourth Circuit court did not agree with Hustler’s position that Falwell needed proof of Hustler’s genuine malice to be awarded damages for emotional distress. Whether the advertisement was outrageous enough to cause emotional distress was in question. The Supreme Court of the United States issued certiorari.
Issue
To what extent did true malice justify awarding damages to a well-known individual for the intentional infliction of emotional distress, or did such damages come from a deliberate refusal to acknowledge the truth?
Holding and Conclusion
No.
The review concluded that the respondent, as a public person, was responsible for proving that the assertions in the advertising parody were made with genuine malice or reckless contempt for the truth. Damages were denied because the court has a historical policy of not allowing them whenever someone claims that any sort of speech caused them mental distress. As a result, the Court of Appeals’ ruling was overturned.
The Supreme Court concluded that upholding the lower court’s decision would have far-reaching consequences for political humor. When public officials and celebrities could not establish that the publication was done maliciously, they were found guilty of causing irreparable emotional harm. Despite its poor taste, a parody is not evil.
Reasoning and Analysis
In this landmark case, the Supreme Court of the United States ruled that a public figure cannot sue for damages for the tort of intentional infliction of emotional distress (IIED) if their distress was caused by a caricature, parody, or satire of them that a reasonable person would not have taken to be factual.
According to the ruling, famous persons like Jerry Falwell are barred from suing for defamation if they cannot prove that the publication included a knowingly false statement of fact (what the law calls “actual malice”). The court went on to say that the state’s interest in protecting public figures from manifestly offensive statements was outweighed by the interest of preserving free expression under the First Amendment, so long as the speech in question could not be fairly interpreted to disclose facts about its topic.
The Supreme Court vacated the Court of Appeals’ decision that had upheld the minister’s award of damages, reiterating the importance of the free flow of ideas and opinions at the heart of the First Amendment and stating that the type of expression that had been challenged did not fall within any of the exceptions to First Amendment protection.
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