22 N.Y.2d 818 (1968)
To recover damages for defamation, a public figure must prove that the defendant published the defamatory statements with actual malice, meaning with knowledge that the statements were false or with reckless disregard for whether they were true or false.
Summary
Linus Pauling, a well-known public figure, sued National Review for defamation. The New York Court of Appeals affirmed the dismissal of Pauling’s complaint, holding that he failed to demonstrate that the defendants acted with actual malice. The court emphasized that, under the First Amendment as interpreted in New York Times Co. v. Sullivan, public figures must prove that defamatory statements were published with knowledge of their falsity or with reckless disregard for the truth. The court found no evidence that National Review acted with the requisite level of fault.
Facts
Linus Pauling was a prominent and controversial public figure. National Review published statements that Pauling claimed were defamatory. Pauling then sued National Review, alleging defamation.
Procedural History
The lower courts dismissed Pauling’s complaint. Pauling appealed to the New York Court of Appeals.
Issue(s)
Whether a public figure, in order to recover damages for defamation, must prove that the defendant published the defamatory statements with actual malice – that is, with knowledge that they were false or with reckless disregard for whether they were true or false.
Holding
Yes, because the First Amendment, as interpreted by the Supreme Court in New York Times Co. v. Sullivan, requires public figures to prove actual malice in order to recover damages for defamation.
Court’s Reasoning
The court relied heavily on New York Times Co. v. Sullivan and its progeny, which established the actual malice standard for defamation cases involving public figures. The court stated, “The statements which they made concerned one who, concededly, was and is a ‘public figure’. (See Curtis Pub. Co. v. Butts, 388 U. S. 130, 162.) Accordingly, we need go no further than to say that we find, as did the courts below, that the plaintiff failed to establish the fact, essential to the cause of action, that the defendants published the statements in question either with ‘knowledge’ of their falsity or with ‘reckless disregard’ of whether they were true or false (New York Times Co. v. Sullivan, 376 U. S. 254, 279-280; see, also, Pickering v. Board of Educ., 391 U. S. 563, 573) or with a ‘high degree of awareness’ of their probable falsity (Garrison v. Louisiana, 379 U. S. 64, 74) or that the defendants ‘in fact’ entertained ‘serious doubts’ as to their truth. (St. Amant v. Thompson, 390 U. S. 727, 731.)” The court found that Pauling had not presented sufficient evidence to demonstrate that National Review acted with the requisite level of fault. This case reinforces the high burden that public figures face when bringing defamation claims, requiring them to prove not only that the statements were false and defamatory, but also that they were published with actual malice. This standard is designed to protect freedom of speech and the press, even when that speech is critical of public figures. The ruling underscores the importance of a free press in a democratic society, even if that means some degree of potentially harmful falsehood is tolerated. The court’s decision reflects a balancing of interests between protecting reputation and promoting robust public discourse.