390 U.S. 727 (1968)
On June 27, 1962, petitioner St. Amant, a candidate for public office, delivered a televised speech in Baton Rouge, Louisiana, during which he read a series of questions he had posed to J. D. Albin, a member of a Teamsters Union local, along with Albin's answers concerning the activities of E. G. Partin, the local's president, and Partin's alleged ties to St. Amant's political opponent.1
One of Albin's answers referenced Herman A. Thompson, an East Baton Rouge Parish deputy sheriff, stating that the union knew of money that had passed from Partin to Thompson and of Thompson's connections with the sheriff's office, which prevented them from seeking help there.2
Thompson promptly filed suit against St. Amant for defamation, claiming the publication imputed gross misconduct.3 The case was tried before the Supreme Court's decision in New York Times Co. v. Sullivan, and the trial judge ruled in Thompson's favor, awarding $5,000 in damages.4
After the New York Times decision, the trial court considered the motion for new trial but upheld the judgment.5 The Louisiana Court of Appeal reversed, finding insufficient evidence of actual malice.6 The Louisiana Supreme Court then reversed the appellate court, concluding there was sufficient evidence of reckless disregard.7
The U.S. Supreme Court granted certiorari.8 For purposes of the case, the determinations that the material charged Thompson with criminal conduct, that the charge was false, and that Thompson was a public official are accepted.9
Whether the Louisiana Supreme Court correctly interpreted and applied the actual malice standard from New York Times Co. v. Sullivan when it sustained a judgment for damages in a public official's defamation action?10
Under the actual malice standard, a public official plaintiff must prove that the defamatory publication was made with knowledge that it was false or with reckless disregard of whether it was false or not.11 Reckless disregard requires sufficient evidence that the defendant in fact entertained serious doubts as to the truth of the publication and is not measured by whether a reasonably prudent person would have published or investigated before publishing.12
No. The established facts demonstrate that St. Amant lacked the requisite awareness of probable falsity when he broadcast Albin's statements about Thompson.13 St. Amant had known Albin since October 1961, had verified other aspects of Albin's information, and relied on an affidavit that Albin swore to both in writing and before newsmen.14 Nothing in the record indicates that St. Amant entertained serious doubts about the truth of the charge that money passed from Partin to Thompson or that Thompson's connections blocked access to the sheriff's office.15 Although St. Amant possessed no personal knowledge and performed no further verification with union officials, the absence of investigation alone does not establish bad faith.16
The Louisiana Supreme Court misapplied the actual malice standard, and the judgment awarding damages to Thompson must be reversed.17
Related opinions on this issue
Justice Fortas dissented on the ground that St. Amant failed to satisfy the minimal standards of care specified by New York Times Co. v. Sullivan.18 Fortas viewed the broadcast of the seriously libelous statement directed against Thompson as a casual, careless, and callous use of libel that could not be rationalized as resulting from the heat of a campaign.19 In Fortas's view, this libel was broadcast with actual malice, with reckless disregard of whether it was false or not, so the judgment allowing recovery should have been affirmed under the principle of Curtis Publishing Co. v. Butts.20
Fortas emphasized that petitioner had a duty to check the reliability of the libelous statement about respondent before broadcasting it.21 Since St. Amant made no such check, Fortas agreed with the Supreme Court of Louisiana that New York Times does not prohibit recovery.22