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Harte-Hanks Communications, Inc. v. Connaughton

United States Supreme Court

491 U.S. 657 (1989)

Relevant factsFree

Daniel Connaughton (plaintiff) lost a municipal judge race to incumbent James Dolan. Shortly before the election, the Journal News (defendant) published a story, based on witness Alice Thompson's account, claiming Connaughton had tried to bribe a grand jury witness. Before publishing, the paper interviewed both Thompson (whose taped statements were hesitant and evasive) and Connaughton (who denied wrongdoing). Connaughton also gave the paper a taped interview with another witness, Patsy Stephens, corroborating his denial, but the paper never listened to that tape. Connaughton sued for defamation and won at trial and on appeal.

IssueFree

Whether a defendant's deliberate decision not to ascertain available information about the truth of a statement is sufficient to establish actual malice in a defamation suit by a public official.

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