Rosenbloom v. Metromedia, Inc.

Supreme Court of the United States · 1971 · Torts

403 U.S. 29 (1971)

Updated July 23, 2026

TortsDefamationLibelFirst Amendmentactual maliceknowledge of falsityreckless disregardpublic or general concern

Facts

Petitioner distributed nudist magazines in Philadelphia and was arrested during a police obscenity crackdown; police later searched his home and warehouse and seized books and magazines. Respondent radio station WIP broadcast reports describing the seized books as obscene, and later aired reports about petitioner's federal lawsuit using phrases such as "smut literature racket" and "girlie-book peddlers." Petitioner was later acquitted of the obscenity charges, and then brought this libel action alleging the broadcasts were false and defamatory. At trial, the station relied primarily on information supplied by police officials, and the jury found for petitioner under Pennsylvania standards that allowed recovery without requiring proof of knowing or reckless falsity.

Issue

When a private individual brings a state libel action against a news broadcaster for defamatory falsehoods concerning his involvement in an event of public or general interest, does the First Amendment require proof only of failure to use reasonable care, or does it require proof that the falsehood was published with knowledge of falsity or reckless disregard for truth?

Rule

A libel action by a private individual against a news media defendant for a defamatory falsehood relating to the individual's involvement in an event of public or general concern may be sustained only upon clear and convincing proof that the falsehood was published with knowledge that it was false or with reckless disregard of whether it was false or not.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Cleveland, a local television station reported that private resident Nina Patel had been detained during a citywide crackdown on illegal dumping near the Cuyahoga River. The report falsely stated that she had been caught transporting toxic waste, when she had actually been stopped while delivering landscaping supplies.

If Nina sues the station for defamation, what constitutional showing must she make to recover damages?

Explanation. Under the majority opinion, the First Amendment standard turns on whether the publication concerns a matter of public or general concern, not on whether the plaintiff is famous or private. When a private individual sues a news media defendant over a defamatory falsehood relating to such a matter, recovery requires clear and convincing proof of knowledge of falsity or reckless disregard of truth. Ill will is not the constitutional test.