# United States: Montgomery, Alabama commissioner sues The New York Times for libel over a civil rights advertisement

Published 2026-09-26. Last reviewed 2026-09-26. 2 sources.

Status: historical, as of 2026-09-26.

L. B. Sullivan, an elected Montgomery, Alabama city commissioner who supervised the police department, sued The New York Times for libel over a 1960 civil rights advertisement and won a $500,000 jury verdict. On March 9, 1964, the Supreme Court of the United States reversed the judgment, ruling that a public official cannot recover libel damages over criticism of official conduct without proving the statement was made with actual malice.[1][2][3]

- Country: [United States](https://thewaronnews.com/countries/us) (RSF 2026 rank: 64th of 180)
- Where: United States
- Level of government: State or province
- Tactics: Lawsuits against the press, Insult and defamation laws
- Stage: Punish (ladder: https://thewaronnews.com/ladders/lawsuits_against_press#stage-punish)
- Head of government at the time: [John Patterson](https://thewaronnews.com/leaders/john-patterson)
- Issue of the day: The advertisement had described police actions against civil rights demonstrators who supported the Reverend Martin Luther King Jr. in Montgomery, and Sullivan, who supervised the police department, considered the description a reflection on him personally.
- Outcome: Reversed, 9 March 1964. The Supreme Court of the United States reversed the Alabama libel judgment on March 9, 1964, and remanded the case for further proceedings consistent with its opinion.
- Era: The 1960s

## What happened

L. B. Sullivan, the elected Commissioner of Public Affairs for the city of Montgomery, Alabama, supervised the city's police department. In 1960, The New York Times published a full-page advertisement soliciting funds for the civil rights movement that described police actions against demonstrators supporting the Reverend Martin Luther King Jr. Sullivan brought a civil libel action against the newspaper and four individual petitioners in the Circuit Court of Montgomery County, testifying that any description of police action reflected on him personally. Under Alabama law, Sullivan needed only to show the advertisement contained errors that could have harmed his reputation; the jury awarded him $500,000, the full amount he sought, and the Supreme Court of Alabama affirmed. The New York Times asked the Supreme Court of the United States, the country's highest court, to review the judgment. On March 9, 1964, the Court ruled unanimously in New York Times Co. v. Sullivan that the Constitution's guarantees of speech and press bar a public official from recovering libel damages over criticism of official conduct unless the official proves the statement was made with actual malice, meaning with knowledge it was false or with reckless disregard for the truth. The Court reversed the Alabama judgment and remanded the case.[1][2][4][5][6][7][3]

## What reason was given

Sullivan testified that because his duties included supervision of the police department, any published description of police action reflected on him personally, and Alabama law let him recover damages without proving the advertisement's errors were made knowingly or recklessly.[4][5]

## What changed for reporting

The Supreme Court's ruling required any public official suing over criticism of official conduct to prove the challenged statement was made with actual malice, meaning with knowledge it was false or with reckless disregard for the truth.[6]

## Timeline

- 1960: United States: Montgomery, Alabama commissioner sues The New York Times for libel over a civil rights advertisement

## Who acted

| Name | Role in this incident | Office at the time |
| --- | --- | --- |
| [L. B. Sullivan](https://thewaronnews.com/actors/l-b-sullivan) | other | Commissioner of Public Affairs, City of Montgomery, Alabama |

## Outlets and journalists

| Name | Kind | Relation |
| --- | --- | --- |
| [The New York Times](https://thewaronnews.com/outlets/new-york-times-historical) | outlet | affected |

## Sources

1. New York Times Co. v. Sullivan, 376 U.S. 254 (1964). https://www.law.cornell.edu/supremecourt/text/376/254 (Cornell Law School, Legal Information Institute, 1964-03-09).
2. New York Times Co. v. Sullivan (1964). https://firstamendment.mtsu.edu/article/new-york-times-co-v-sullivan/ (The First Amendment Encyclopedia, Middle Tennessee State University, 2023-08-06).

## Claims cited

[1] Sullivan's complaint arose from a full-page advertisement carried in The New York Times on March 29, 1960, and he filed his libel suit later that year. Quote: "Respondent's complaint alleged that he had been libeled by statements in a full-page advertisement that was carried in the New York Times on March 29, 1960." Source: Cornell Law School, Legal Information Institute, 1964-03-09. New York Times Co. v. Sullivan, 376 U.S. 254 (1964). https://www.law.cornell.edu/supremecourt/text/376/254 Claim: https://thewaronnews.com/claims/821, checked 2026-09-26.

[2] A Montgomery County jury awarded Sullivan $500,000, the full amount he sought from The New York Times and four individual petitioners, and the Supreme Court of Alabama affirmed the judgment. Quote: "A jury in the Circuit Court of Montgomery County awarded him damages of $500,000, the full amount claimed, against all the petitioners, and the Supreme Court of Alabama affirmed." Source: Cornell Law School, Legal Information Institute, 1964-03-09. New York Times Co. v. Sullivan, 376 U.S. 254 (1964). https://www.law.cornell.edu/supremecourt/text/376/254 Claim: https://thewaronnews.com/claims/822, checked 2026-09-26.

[3] The lawsuit was filed by L. B. Sullivan, an elected city commissioner in Montgomery, Alabama, whose duties included supervision of the local police. Quote: "The lawsuit was filed by L. B. Sullivan, an elected city commissioner in Montgomery, Alabama, whose duties included supervision of the local police." Source: The First Amendment Encyclopedia, Middle Tennessee State University, 2023-08-06. New York Times Co. v. Sullivan (1964). https://firstamendment.mtsu.edu/article/new-york-times-co-v-sullivan/ Claim: https://thewaronnews.com/claims/827, checked 2026-09-26.

[4] Sullivan testified that because his duties included supervising the police department, he considered any description of police conduct a reflection on him personally. Quote: "When it describes police action, certainly I feel it reflects on me as an individual." Source: Cornell Law School, Legal Information Institute, 1964-03-09. New York Times Co. v. Sullivan, 376 U.S. 254 (1964). https://www.law.cornell.edu/supremecourt/text/376/254 Claim: https://thewaronnews.com/claims/823, checked 2026-09-26.

[5] Under Alabama law as it stood before the Supreme Court's ruling, Sullivan needed only to show the advertisement contained errors that could have harmed his reputation. Quote: "Under Alabama law, Sullivan only needed to prove that there were mistakes and that they likely harmed his reputation." Source: The First Amendment Encyclopedia, Middle Tennessee State University, 2023-08-06. New York Times Co. v. Sullivan (1964). https://firstamendment.mtsu.edu/article/new-york-times-co-v-sullivan/ Claim: https://thewaronnews.com/claims/824, checked 2026-09-26.

[6] The Supreme Court held that a public official may not recover libel damages over criticism of official conduct unless the official proves the statement was made with actual malice, that is, with knowledge it was false or with reckless disregard for the truth. Quote: "unless he proves that the statement was made with 'actual malice'—that is, with knowledge that it was false or with reckless disregard of whether it was false or not." Source: Cornell Law School, Legal Information Institute, 1964-03-09. New York Times Co. v. Sullivan, 376 U.S. 254 (1964). https://www.law.cornell.edu/supremecourt/text/376/254 Claim: https://thewaronnews.com/claims/825, checked 2026-09-26.

[7] The Supreme Court of the United States reversed the judgment of the Supreme Court of Alabama and remanded the case for further proceedings. Quote: "The judgment of the Supreme Court of Alabama is reversed and the case is remanded to that court for further proceedings not inconsistent with this opinion." Source: Cornell Law School, Legal Information Institute, 1964-03-09. New York Times Co. v. Sullivan, 376 U.S. 254 (1964). https://www.law.cornell.edu/supremecourt/text/376/254 Claim: https://thewaronnews.com/claims/826, checked 2026-09-26.

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