Harte-Hanks Communications, Inc. v. Connaughton

How later courts described this case

• 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 finding actual malice”; and affirming verdict for plaintiff where defendant had, before publication, interviewed multiple witnesses who contradicted challenged statement and had recording of interview of key witness to events that defendant did not review
• 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” with another newspaper that would be impugned by discrediting the plaintiff
• 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 degree of awareness of . . . probable falsity"
• 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 citation omitted)

Written by the judges who cited it.