''Rosenbloom v. Metromedia, Inc.'', 403 U.S. 29 (1971), was a
United States Supreme Court case of
libel
Defamation is the act of communicating to a third party false statements about a person, place or thing that results in damage to its reputation. It can be spoken (slander) or written (libel). It constitutes a tort or a crime. The legal defini ...
brought by George Rosenbloom against
Metromedia.
[.] This case was responsible for establishing the idea that the knowingly and
recklessly false standard (known as the "actual malice" test) for defamatory statements should apply to private individuals as well as public officials in matters of public concern. Concluding that the story was a matter of public concern, the Supreme Court ruled that it did not matter that Rosenbloom was a private citizen; however, the evidence provided in the case did not support the
damages awarded to Rosenbloom. The decision was made June 7, 1971 with a 5-3 decision.
Background
A byproduct of the
First Amendment, the court had been forced to provide limitations outlining the offense of libel. This was the topic of a series of court cases, two of the most famous being ''
New York Times Co. v. Sullivan
''New York Times Co. v. Sullivan'', 376 U.S. 254 (1964), was a landmark U.S. Supreme Court decision ruling that the First Amendment to the U.S. Constitution's freedom of speech protections limit the ability of American public officials to sue for ...
'' and ''
Gertz v. Robert Welch, Inc.
''Gertz v. Robert Welch, Inc.'', 418 U.S. 323 (1974), was a landmark decision of the US Supreme Court establishing the standard of First Amendment protection against defamation claims brought by private individuals. The Court held that, so long ...
''.
[.] At the focal point of these cases was the "knowingly and recklessly false" requirement, which had been used to protect public officials from libel. After raiding his home, George Rosenbloom was arrested in Philadelphia in October 1963 for distribution of
nudist magazines, and a news outlet that reported every half-hour broadcast reported on the arrest of George Rosenbloom using his name when talking about police seizure of "
obscene books".
Later stories run by Metromedia excluded Rosenbloom's name, when using language such as "girlie look peddlers" and "smut distributors".
[ After his acquittal of criminal obscenity charges in May 1964,]
Decision
The Supreme Court made a 5-3 majority decision that upheld the ruling as it was made in the United States Court of Appeals for the Third Circuit. In conjunction with the decision being upheld, the Supreme Court reduced the punitive damages from the originally-awarded $725,000 to $250,000.
References
Further reading
*
External links
* {{caselaw source
, case = ''Rosenbloom v. Metromedia, Inc.'', {{ussc, 403, 29, 1971, el=no
, cornell =https://www.law.cornell.edu/supremecourt/text/403/29
, courtlistener =https://www.courtlistener.com/opinion/108361/rosenbloom-v-metromedia-inc/
, googlescholar = https://scholar.google.com/scholar_case?case=13134064098406124246
, justia =https://supreme.justia.com/cases/federal/us/403/29/
, loc =http://cdn.loc.gov/service/ll/usrep/usrep403/usrep403029/usrep403029.pdf
, oyez =https://www.oyez.org/cases/1970/66
Case Summary
1971 in United States case law
United States defamation case law
United States Supreme Court cases
United States Supreme Court cases of the Burger Court
Metromedia