Hak V Connaughton Case Study
I. Case Name:
Harte-Hanks Communications Inc. v. Connaughton (1989). This civil law case refined the actual malice standard.
II. Summary of Facts:
In November 1983, Connaughton ran for the position of Municipal Judge of Hamilton, Ohio, and lost to James Dolan. Dolan resigned from the position a month later and was arrested for perjury charges. While an investigation took place, the Journal News ran an article quoting Alice Thompson, a witness, saying Connaughton had used his “dirty tricks” and offered Thompson and her sister benefits “in appreciation” for Thompson’s testimony. Connaughton claimed Harte-Hanks Communications’ (HHC) article was false and had defamed him, injuring his personal, political, and professional reputation. HHC then …show more content…
The allegations were contradicted by other people within the trial. The jury saw that there was not enough evidence supporting that it was a clear print mistake, and that it instead was a act of malice.
The court referenced New York Times v. Sullivan and Bose Corp v. Consumers Union of the United States while examining the case in front of them. In Bose v. Consumers Union, actual malice was not determined solely by Rule 52(a), and that the court must perform a de novo review. In Times v. Sullivan,
“The evidence adduced at trial demonstrated that the Journal was motivated to publicize Thompson's allegations, not only by a desire to establish its preeminence in the reporting of Hamilton political news, but also by a desire to aid the Dolan campaign.” (Leagle.com: Harte Hanks Comm. V. Conn. [842 F.2d 847]). This quote leads us to believe that Journal News knew exactly what it was doing when it published the statements. Journal News was trying to publicly humiliate Connaughton and lose him the majority of his followers, possibly costing him his career. Journal News also was said to know that Thompson was not mentally stable and was angry at Connaughton, possibly causing her to lie to
Harte-Hanks Communications Inc. v. Connaughton (1989). This civil law case refined the actual malice standard.
II. Summary of Facts:
In November 1983, Connaughton ran for the position of Municipal Judge of Hamilton, Ohio, and lost to James Dolan. Dolan resigned from the position a month later and was arrested for perjury charges. While an investigation took place, the Journal News ran an article quoting Alice Thompson, a witness, saying Connaughton had used his “dirty tricks” and offered Thompson and her sister benefits “in appreciation” for Thompson’s testimony. Connaughton claimed Harte-Hanks Communications’ (HHC) article was false and had defamed him, injuring his personal, political, and professional reputation. HHC then …show more content…
The allegations were contradicted by other people within the trial. The jury saw that there was not enough evidence supporting that it was a clear print mistake, and that it instead was a act of malice.
The court referenced New York Times v. Sullivan and Bose Corp v. Consumers Union of the United States while examining the case in front of them. In Bose v. Consumers Union, actual malice was not determined solely by Rule 52(a), and that the court must perform a de novo review. In Times v. Sullivan,
“The evidence adduced at trial demonstrated that the Journal was motivated to publicize Thompson's allegations, not only by a desire to establish its preeminence in the reporting of Hamilton political news, but also by a desire to aid the Dolan campaign.” (Leagle.com: Harte Hanks Comm. V. Conn. [842 F.2d 847]). This quote leads us to believe that Journal News knew exactly what it was doing when it published the statements. Journal News was trying to publicly humiliate Connaughton and lose him the majority of his followers, possibly costing him his career. Journal News also was said to know that Thompson was not mentally stable and was angry at Connaughton, possibly causing her to lie to