Case Overview

Legal Principle at Issue

Are public figures subject to the actual malice standard for libel as articulated in New York Times v. Sullivan (1964)?


Reversed and remanded. Walker’s damages award was overturned.


Edwin Walker, a retired U.S. general, was reported by the Associated Press to have “[a]ssumed command” of a crowd of anti-desegregation protests at the University of Mississippi and led them in a charge against the U.S. Marshals. The story was published by newspapers subscribing to the Associated Press, and Walker sued for libel and was awarded compensatory damages. This was a companion case to Curtis Pub. Co. v. Butts (1967).

Importance of Case

The Court held that Walker was a “public figure,” given “his personal activity amounting to a thrusting of his personality into the ‘vortex’ of an important public controversy.” The Court reasoned that public figures who are not public officials may recover damages for libel stemming from false reports based on “highly unreasonable conduct constituting an extreme departure from the standards of investigation and reporting ordinarily adhered to by responsible publishers.” This is a lesser standard than “actual malice” required for public officials under New York Times v. Sullivan (1964).

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