Liberty Lobby, Inc. (Liberty), a nonprofit "citizen's lobby" corporation, filed a libel action against a magazine published by Jack Anderson et al. Liberty claimed that one of Anderson's articles contained false and derogatory statements about its operations. In its defense, Anderson claimed that as a pubic entity Liberty must show with "convincing clarity" that Anderson acted with actual malice - something they could not do since the article's author stated in an affidavit that he thoroughly researched and cross-checked all his information. Liberty claimed that Anderson did act with actual malice since its author depended on patently unreliable sources. Following a district court's summary judgment ruling favoring Anderson, an appellate court reversed as it held that the lower court erroneously applied actual malice standards of proof at the summary judgement phase. Anderson appealed and the Supreme Court granted certiorari.
Can a court, in the context of a summary judgment request, award summary judgment in a libel action if the moving party had no evidence that a reasonable jury might disbelieve its opponent's claim?
No. In a 6-to-3 opinion, the Court held that the purpose of summary judgments is to determine if the evidence is so one-sided that a party should prevail as a matter of law. Summary judgments will not lie if there is a sufficient likelihood that a reasonable jury would return a verdict favorable to the nonmoving party. In libel cases involving public entities, trial courts faced with summary judgment motions must decide whether a reasonable jury could conclude with convincing clarity that actual malice existed. The mere assertion by a plaintiff that a defendant's summary judgment motion is deficient because a reasonable jury might disbelieve the defendant's denial of actual malice is insufficient to warrant a grant of summary judgment without any offer of evidentiary proof to that effect. The Court reversed the appellate court's decision and remanded for reconsideration of its summary judgment ruling.
Decisions
Decision: 6 votes for Anderson, 3 vote(s) against Legal provision: Federal Rules of Civil Procedure, including Appellate Procedure (or relevant rules of a circuit court)
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Full Opinion by Justice Byron R. White
