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Keywords

plaintiffdefendantdamagesliabilitytrialverdictburden of proof
plaintiffdamagescorporationappellantappellee

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Philadelphia Newspapers, Inc. v. Hepps, 475 U.S. 767, 106 S.Ct. 1558, 89 L.Ed.2d 783, 54 USLW 4373, 12 Media L. Rep. 1977

Facts

Maurice S. Hepps, the principal stockholder of General Programming, Inc., which franchises a chain of stores selling beer and snacks, sued the Philadelphia Inquirer for defamation after it published articles suggesting that he and his franchisees had connections to organized crime. The articles claimed that Hepps used these connections to influence state government processes. The trial court ruled that the burden of proof for falsity lay with Hepps, leading to a jury verdict in favor of the newspaper. The Pennsylvania Supreme Court later reversed this ruling, stating that the burden of proving falsity should rest with the plaintiff in cases involving public concern.

Appellee Hepps is the principal stockholder of appellee corporation that franchises a chain of stores selling beer, soft drinks, and snacks. Appellant owner published a series of articles in its Philadelphia newspaper whose general theme was that Hepps, the franchisor corporation, and its franchisees (also appellees) had links to organized crime and used some of those links to influence the State's governmental processes.

Issue

Whether a private figure plaintiff alleging defamation must prove the falsity of the statements made about them in matters of public concern.

Whether a private figure plaintiff alleging defamation must prove the falsity of the statements made about them in matters of public concern.

Rule

In cases involving speech of public concern, a private figure plaintiff cannot recover damages for defamation without proving that the statements at issue are false.

In a case such as this one, where a newspaper publishes speech of public concern about a private figure, the private-figure plaintiff cannot recover damages without also showing that the statements at issue are false.

Analysis

The court applied the rule by emphasizing the need to protect true speech on matters of public concern. It reasoned that placing the burden of proving falsity on the plaintiff aligns with constitutional protections for free speech, ensuring that true statements are not deterred by the fear of liability. The court noted that the common-law presumption that defamatory speech is false cannot stand when a plaintiff seeks damages against a media defendant for speech of public concern.

To ensure that true speech on matters of public concern is not deterred, the common-law presumption that defamatory speech is false cannot stand.

Conclusion

The Supreme Court reversed the Pennsylvania Supreme Court's decision and remanded the case for further proceedings, holding that the private-figure plaintiff must bear the burden of proving falsity in defamation cases involving public concern.

The judgment of the Pennsylvania Supreme Court is reversed, and the case is remanded for further proceedings not inconsistent with this opinion.

Who won?

The prevailing party was the Philadelphia Inquirer and its reporters, as the court ruled in their favor by reversing the previous decision that placed the burden of proof on them.

The jury ruled for appellants and therefore awarded no damages to appellees.

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