St. Amant v. Thompson

Supreme Court of the United States · 1968 · Torts

390 U.S. 727 (1968)

Updated July 23, 2026

TortsDefamationFirst AmendmentPublic official libelpublic officialactual malicereckless disregardprobable falsity

Facts

During a televised campaign speech, St. Amant read questions and answers attributed to J. D. Albin, a dissident Teamsters local member, about alleged wrongdoing by union president E. G. Partin. In one answer, Albin stated that money had passed from Partin to Thompson, an East Baton Rouge Parish deputy sheriff, and referred to Thompson's connections with the sheriff's office. Thompson sued for defamation, and for purposes of the case the Court accepted that the broadcast falsely charged Thompson with criminal conduct and that Thompson was a public official. St. Amant had no personal knowledge of Thompson's activities, relied on Albin's sworn statement, and had known Albin since the prior year while investigating union disputes.

Issue

Whether the evidence was sufficient to show that St. Amant made the false defamatory statements about a public official with actual malice under New York Times v. Sullivan. More specifically, the question was whether St. Amant acted with reckless disregard for whether the statements were true or false.

Rule

In a public official's defamation action, actual malice requires proof that the defendant published the statement with knowledge of falsity or with reckless disregard for truth or falsity. Reckless disregard is not measured by whether a reasonably prudent person would have investigated or published; instead, there must be sufficient evidence that the defendant in fact entertained serious doubts as to the truth of the publication or had a high degree of awareness of probable falsity.

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

During a mayoral debate in Cleveland, candidate Nora Patel states that Police Chief Evan Morris took cash from nightclub owners. She is relying on a signed statement from Leo Mercer, a longtime neighborhood activist she has worked with before, and Mercer publicly repeats the accusation the next day. Patel did not investigate further and had no personal knowledge of the alleged payments.

If the police chief sues and falsity is established, which is the strongest argument that Patel did not act with actual malice?

Explanation. The governing rule requires proof that the defendant knew the statement was false or in fact entertained serious doubts about its truth, or had a high degree of awareness of probable falsity. The majority opinion makes clear that lack of personal knowledge and failure to investigate do not by themselves establish reckless disregard, especially where the speaker relies on a known source without obvious reasons to doubt the source's veracity or report accuracy.