GARRISON v. LOUISIANA

Legal Principle at Issue

Whether the conviction of a district attorney for criminal defamation under the Louisiana Criminal Defamation Statute violated the First Amendment.

Action

The Supreme Court of the United States reversed the Supreme Court of Louisiana, which had held that the law did not violate the First Amendment.

Facts/Syllabus

The District Attorney of Orleans Parish, Louisiana, was convicted by a state court for defamation, principally for attributing “a large backlog of pending criminal cases to the inefficiency, laziness, and excessive vacations of the judges” and stating that “by refusing to authorize disbursements to cover the expenses of undercover investigations of vice in New Orleans, the judges had hampered his efforts to enforce the vice laws.”

Importance of Case

The Supreme Court extended the New York Times Co. v. Sullivan (1964) rule on civil claims of libel related to public officials, which allows a remedy only if the plaintiff can establish “that the utterance was false and that it was made with knowledge of its falsity or in reckless disregard of whether it was false or true,” to include criminal charges. The Court remarked: “The reasons which led us so to hold in New York Times apply with no less force merely because the remedy is criminal.” The Court also held that even though the district attorney’s claims implicated the private character of the judges, “the New York Times rule is not rendered inapplicable merely because an official’s private reputation, as well as his public reputation, is harmed.”