Summary
The Supreme Court of Texas held that media defendants Hearst Corporation and Evan Moore were entitled to summary judgment in a defamation action brought by public-figure prosecutors. The court concluded that the plaintiffs failed to raise a fact issue showing actual malice, including knowledge of falsity or reckless disregard for the truth, and rendered judgment for the defendants.
Topics
Practice areas
Questions Presented
- Whether public-figure plaintiffs raised a fact issue that the media defendants published the article with actual malice.
- Whether the media defendants were entitled to summary judgment on the plaintiffs' libel claim.
Holdings
- The plaintiffs failed to raise a fact issue that Hearst and Moore published the article with knowledge of falsity or reckless disregard for the truth.
- The media defendants were entitled to summary judgment, and judgment was rendered in their favor.
Key quotations
“A failure to investigate fully is not evidence of actual malice; a purposeful avoidance of the truth is.” (637)
“Although the filmmakers did not interview [the father or his lawyers], they were not required to continue their research until they could find one more person who agreed with [the judge's] order.” (638)
“An understandable misinterpretation of ambiguous facts does not show actual malice, but inherently improbable assertions and statements made on information that is obviously dubious may show actual malice.” (638)
“The mere fact that a defamation defendant knows that a public figure has denied harmful allegations or offered an alternative explanation of events is not evidence that the defendant doubted the allegations.” (639)
Factual background
Hearst published a Houston Chronicle article criticizing the Smith County criminal justice system and alleging that prosecutors had been accused of suppressing evidence, encouraging perjury, and practicing selective prosecution. Three Smith County prosecutors named in the article sued for libel. The article was based on five months of research, interviews with more than twenty attorneys, court records, and other documents concerning alleged prosecutorial misconduct.
Procedural history
Three Smith County prosecutors sued Hearst Corporation and Evan Moore for libel based on an article criticizing the Smith County criminal justice system. The trial court denied the defendants' motion for summary judgment, and the court of appeals affirmed. The Supreme Court of Texas granted review, reversed the court of appeals, and rendered summary judgment for the defendants.