Harte-Hanks Communications, Inc. v. Connaughton
United States Supreme Court
491 U.S. 657 (1989)
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.
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.