Defendant, a district attorney, issued a statement to the press accusing eight parish judges of laziness, inefficiency in office, taking excessive vacations, and hindering his enforcement of the state's vice laws. Louisiana convicted defendant of a violation of a Criminal Defamation Statute, rejecting his argument that the statute violated the first amendment guarantee of free speech. On appeal to the United States Supreme Court, held: The first amendment is violated by a state statute which permits punishment of (1) truthful criticism of public officials, or (2) false statements about public officials made with ill will, but without knowledge of the falsity or not in reckless disregard of their truth or falsity. Garrison v. Louisiana, 379 U.S. 64 (1964).
New York Times Rule Extended to Criminal Libel,
Wash. L. & Rev.
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