71 N.Y.2d 31 (1987)
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In a defamation case involving a public figure, a finding of “actual malice” (knowledge of falsity or reckless disregard for the truth) must be supported by clear and convincing evidence, and appellate courts must independently review the record to ensure this standard is met.
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Summary
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A high school football coach, Jeremiah Mahoney, sued a reporter and newspaper publisher for libel after an article claimed he verbally abused his players. Mahoney, conceded to be a public figure, had to prove “actual malice.” The New York Court of Appeals reversed the lower court’s ruling in favor of Mahoney, finding insufficient evidence that the reporter knew the statements were false or recklessly disregarded the truth. The court emphasized the need for clear and convincing evidence of actual malice and independent appellate review to protect free speech.
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Facts
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Thomas Bengston, a reporter, wrote an article criticizing football coach Jeremiah Mahoney’s behavior during a game. The article stated Mahoney “cursed and belittled his players” and quoted him as saying to his quarterback,