# Harte-Hanks Communications, Inc. v. Connaughton

> Supreme Court of the United States · June 22, 1989 · 491 U.S. 657

URL: https://www.frixlaw.com/law-library/cases/9431785

## Case

- **Full name:** Harte-Hanks Communications, Inc. v. Connaughton
- **Court:** Supreme Court of the United States
- **Decided:** June 22, 1989
- **Citations:** 491 U.S. 657; 16 Media L. Rep. (BNA) 1881; 57 U.S.L.W. 4846; 109 S. Ct. 2678; 105 L. Ed. 2d 562; 1989 U.S. LEXIS 3133; 1989 WL 65717
- **Precedential status:** Published
- **Opinion:** Concurrence by White
- **Judges:** Kennedy, Scalia, Stevens, White, Blackmun
- **Cited by:** 907 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/9431785

## How later opinions describe it (automated extraction)

- holding that “public figure plaintiff must prove more than an extreme departure from professional standards[,] and [] a newspaper’s motive in publishing a story – whether to promote an opponent’s candidacy or to increase its circulation – cannot provide a sufficient basis for …
- stating that “it cannot be said that evidence concerning motive or care never bears any relation to the actual malice inquiry,” and noting that jury could have found actual malice on the basis, inter alia, that publisher was biased against plaintiff and in a “bitter rivalry” w…
- holding that the standard for "reckless disregard" for the truth in a defamation action by a public figure "is a subjective one," requiring that "the defendant in fact entertained serious doubts as to the truth of his publication," or that "the defendant actually had a high de…
- explaining that reckless disregard for the truth at a minimum means that “the defendant must have made the false publication with a high degree of awareness of . . . probable falsity, or must have entertained serious doubts as to the truth of his publication” (quotations and c…
- holding that evidence supported a finding of actual malice of a newspaper defendant based on the fact that several people had told the defendant the charges were not true and also the fact that the informant’s demeanor when providing the information raised “obvious doubts abou…

## Opinion text

*694 Justice White,
with whom The Chief Justice joins,
concurring.
In my view, in cases like this the historical facts — e. g., who did what to whom and when — are re viewable only under the clearly-erroneous standard mandated by Federal Rule of Civil Procedure 52. Credibility determinations fall in this category, as does the issue of knowledge of falsity. But as I observed in dissent in Bose Corp. v. Consumers Union of United States, Inc., 466 U. S. 485, 515 (1984), the reckless disregard component of the New York Times Co. v. Sullivan “actual malice” standard is not a question of historical fact. A trial court’s determination of that issue therefore is to be reviewed independently by the appellate court.
As I read it, the Court’s opinion is consistent with these views, and — as Justice Kennedy observes — is consistent with the views expressed by Justice Scalia in his concurrence. Based on these premises, I join the Court’s opinion.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/9431785. Public record. Not legal advice.