Anderson v. Liberty Lobby, Inc.

Summary

The U.S. Supreme Court held that a court deciding a motion for summary judgment in a defamation case governed by New York Times Co. v. Sullivan must consider the applicable clear-and-convincing evidence standard for actual malice. Summary judgment is improper when the evidence would permit a reasonable jury to find for the nonmoving party under that standard, but a plaintiff may not rely solely on the possibility that the jury will disbelieve the defendant. The Court vacated and remanded the Court of Appeals' judgment.

Holdings

1. In a libel action involving a public figure and governed by New York Times, the court must consider the clear-and-convincing evidentiary standard when determining whether a genuine issue of actual malice exists on summary judgment.
2. A factual dispute is genuine only when the evidence is sufficient for a reasonable jury to return a verdict for the nonmoving party; a mere scintilla of evidence, evidence that is merely colorable, or evidence that is not significantly probative is insufficient.
3. A plaintiff cannot defeat a properly supported summary-judgment motion merely by asserting that the jury might disbelieve the defendant's denial of actual malice; the plaintiff must produce affirmative evidence from which a reasonable jury could return a verdict in the plaintiff's favor.

Questions Presented

1. Whether a court ruling on summary judgment in a libel action governed by New York Times Co. v. Sullivan must consider the requirement that actual malice be shown by clear and convincing evidence.
2. What standard governs whether a genuine issue of material fact exists under Federal Rule of Civil Procedure 56.
3. Whether a plaintiff may defeat a properly supported summary-judgment motion merely by relying on the possibility that the jury could disbelieve the defendant's denial of actual malice.

Disposition

vacated