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11 Indiana opinions name it 2 courts 1970–2023 1 in the last five years
The cases below were cited by Indiana courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Gertz v. Robert Welch, Inc.green2 sentences1999Id. at 343 , 94 S.Ct. at 3008-09 , 41 L.Ed.2d at 807 (noting that “the New York Times rule states an accommodation between th[e] concern [of providing the press and broadcast media with immunity from liability] and the limited state interest present in the context of libel actions brought by public persons” and concluding that “the state interest in compensating injury to the reputation of private individuals requires that a different rule should obtain with respect to them”). 1999Id. at 343 , 94 S.Ct. at 3008-09 , 41 L.Ed.2d at 807 (noting that “the New York Times rule states an accommodation between th[e] concern [of providing the press and broadcast media with immunity from liability] and the limited state interest present in the context of libel actions brought by public persons” and concluding that “the state interest in compensating injury to the reputation of private individuals requires that a different rule should obtain with respect to them”). | 1 | 5 |
Journal-Gazette Co. v. Bandido's, Inc.green2 sentences2023The Court noted that “[w]e have extended the stringent New York Times standard to ‘defamation cases involving matters of public or general concern,’ even if the victim is a private figure.” Id. at 962 (quoting Journal-Gazette, Co. v. Bandido’s, Inc., 712 N.E.2d 446, 449, 452 (Ind. 1999)). [20] Clinging to the words “matters of public or general concern,” the parties argue that the State had to prove actual malice because the Bann is a matter of public or general concern within the Amish community. 2014Bandido’s, 712 N.E.2d at 449 , 452 (citing Aafco Heating & Air Conditioning Co. v. Nw. | 1 | 2 |
New York Times Co. v. Sullivangreen2 sentences1996"Realistically, some error is inevitable; and the difficulties of separating fact from fiction convinced the Court in New York Times, Butts, Gertz [v. Robert Welch, Inc., 418 U.S. 323 , 94 S.Ct. 2997 , 41 L.Ed.2d 789 (1974)] and similar cases to limit liability to instances where some degree of culpability is present in order to eliminate the risk of undue self-censorship and the suppression of truthful material." - Herbert v. Lando, 441 U.S. 153, 171-172 , 99 S.Ct. 1635, 1646-1647 , 60 L.Ed.2d 115 (1979). "[Elrroneous statement is inevitable in free debate, and . must be protected if the free 1996"Realistically, some error is inevitable; and the difficulties of separating fact from fiction convinced the Court in New York Times, Butts, Gertz [v. Robert Welch, Inc., 418 U.S. 323 , 94 S.Ct. 2997 , 41 L.Ed.2d 789 (1974)] and similar cases to limit liability to instances where some degree of culpability is present in order to eliminate the risk of undue self-censorship and the suppression of truthful material." - Herbert v. Lando, 441 U.S. 153, 171-172 , 99 S.Ct. 1635, 1646-1647 , 60 L.Ed.2d 115 (1979). "[Elrroneous statement is inevitable in free debate, and . must be protected if the free | 1 | 2 |
Schwartz v. WORRALL PUBLICATIONSgreen2 sentences1999The Court additionally stated that this case "represents the sort of inaccuracy that is commonplace in the forum of robust debate to which the New York Times rule applies." Id.; see Chester, 553 N.E.2d at 140 (A negligent interpretation of public records or misconstruction of a statement from a person interviewed falls short of the constitutional requirement of actual malice.). *464 The circumstances in Schwartz v. Worrall Publications, Inc., 258 N.J.Super. 493 , 610 A.2d 425 (1992), [30] are somewhat similar to the circumstances of the case at hand. 1999The Court additionally stated that this case "represents the sort of inaccuracy that is commonplace in the forum of robust debate to which the New York Times rule applies." Id.; see Chester, 553 N.E.2d at 140 (A negligent interpretation of public records or misconstruction of a statement from a person interviewed falls short of the constitutional requirement of actual malice.). *464 The circumstances in Schwartz v. Worrall Publications, Inc., 258 N.J.Super. 493 , 610 A.2d 425 (1992), [30] are somewhat similar to the circumstances of the case at hand. | 1 | 1 |
Fopay v. Noveroskegreen2 sentences1980See generally Fopay v. Noveroske, (1975) 31 Ill.App.3d 182 , 334 N.E.2d 79 and Hollander v. Pan American World Airways, Inc., (D.Md. 1973) 382 F.Supp. 96 (the latter discussing First Amendment law and private defama-tions prior to Gertz.) Nor has an Indiana court interpreted the “actual damages” rule of Gertz as applying to all defamation actions, although we have held in a media case that the New York Times standard of recklessness should be used regardless of whether a public or private individual is defamed, where the statements in question concern an event or topic of general or public int 1980See generally Fopay v. Noveroske, (1975) 31 Ill.App.3d 182 , 334 N.E.2d 79 and Hollander v. Pan American World Airways, Inc., (D.Md. 1973) 382 F.Supp. 96 (the latter discussing First Amendment law and private defama-tions prior to Gertz.) Nor has an Indiana court interpreted the “actual damages” rule of Gertz as applying to all defamation actions, although we have held in a media case that the New York Times standard of recklessness should be used regardless of whether a public or private individual is defamed, where the statements in question concern an event or topic of general or public int | 1 | 1 |
Hollander v. Pan American World Airways, Inc.green1 sentence1980See generally Fopay v. Noveroske, (1975) 31 Ill.App.3d 182 , 334 N.E.2d 79 and Hollander v. Pan American World Airways, Inc., (D.Md. 1973) 382 F.Supp. 96 (the latter discussing First Amendment law and private defama-tions prior to Gertz.) Nor has an Indiana court interpreted the “actual damages” rule of Gertz as applying to all defamation actions, although we have held in a media case that the New York Times standard of recklessness should be used regardless of whether a public or private individual is defamed, where the statements in question concern an event or topic of general or public int | 1 | 1 |
Barry M. Goldwater v. Ralph Ginzburg, Warren Boroson, and Factmagazine, Inc.green2 sentences1978In Goldwater v. Ginzburg, supra, 414 F.2d 324 , the court also found summary judgment to be inappropriate where “the non-moving party filed affidavits and relevant materials to show affirmatively that there was a genuine issue of fact to resolve, the existence of [defendant’s] possible actual malice.” Id. at 338, n. 21 . 1978In Goldwater v. Ginzburg, supra, 414 F.2d 324 , the court also found summary judgment to be inappropriate where “the non-moving party filed affidavits and relevant materials to show affirmatively that there was a genuine issue of fact to resolve, the existence of [defendant’s] possible actual malice.” Id. at 338, n. 21 . | 1 | 1 |
Greenbelt Cooperative Publishing Assn., Inc. v. Breslergreen2 sentences1974Beckley Newspaper Corp. v. Hanks (1967), 389 U.S. 81 , 88 S.Ct. 197 , 19 L.Ed.2d 248 ; see also Greenbelt Cooperative Publishing Assoc. v. Bresler (1970), 398 U.S. 6 , 90 S.Ct. 1537 , 26 L.Ed.2d 6 . 1974Beckley Newspaper Corp. v. Hanks (1967), 389 U.S. 81 , 88 S.Ct. 197 , 19 L.Ed.2d 248 ; see also Greenbelt Cooperative Publishing Assoc. v. Bresler (1970), 398 U.S. 6 , 90 S.Ct. 1537 , 26 L.Ed.2d 6 . | 1 | 1 |
Tilton v. Cowles Publishing Co.green2 sentences1974NOTES [1] A test was developed for ascertaining the identity of a "public official" within the New York Times standard: "[T]hose among the hierarchy of government employees who have, or appear to the public to have, substantial responsibility for or control over the conduct of public and governmental affairs." Rosenblatt v. Baer (1966), 383 U.S. 75, 85 , 86 S.Ct. 669, 676 , 15 L.Ed.2d 597 . [2] See, e.g., Tilton v. Cowles Publishing Co. (1969), 76 Wash.2d 707 , 459 P.2d 8 , cert. denied 399 U.S. 927 , 90 S.Ct. 2238 , 26 L.Ed.2d 792 (1970) (policeman and fireman running for election to a munici 1974NOTES [1] A test was developed for ascertaining the identity of a "public official" within the New York Times standard: "[T]hose among the hierarchy of government employees who have, or appear to the public to have, substantial responsibility for or control over the conduct of public and governmental affairs." Rosenblatt v. Baer (1966), 383 U.S. 75, 85 , 86 S.Ct. 669, 676 , 15 L.Ed.2d 597 . [2] See, e.g., Tilton v. Cowles Publishing Co. (1969), 76 Wash.2d 707 , 459 P.2d 8 , cert. denied 399 U.S. 927 , 90 S.Ct. 2238 , 26 L.Ed.2d 792 (1970) (policeman and fireman running for election to a munici | 1 | 1 |
Griggs v. Duke Power Co.green2 sentences1974See, e.g., Tilton v. Cowles Publishing Co. (1969), 76 Wash. 2d 707 , 459 P.2d 8 , cert. denied 399 U.S. 927 , 90 S.Ct. 2238 , 26 L.Ed.2d 792 (1970), (policeman and fireman running for election to a municipal health and safety board); Arber v. Stahlin (1968), 10 Mich.App. 181 , 159 N.W.2d 154 , cert. denied, 397 U.S. 924 ; 90 S.Ct. 927 , 25 L.Ed.2d 103 (1970) (republican party volunteer workers and precinct delegates); Rose v. Koch (1967), 278 Minn. 235 , 154 N.W.2d 409 (a university professor who was both a noted author and a former state legislator at the time of publication); Grayson v. Curt 1974NOTES [1] A test was developed for ascertaining the identity of a "public official" within the New York Times standard: "[T]hose among the hierarchy of government employees who have, or appear to the public to have, substantial responsibility for or control over the conduct of public and governmental affairs." Rosenblatt v. Baer (1966), 383 U.S. 75, 85 , 86 S.Ct. 669, 676 , 15 L.Ed.2d 597 . [2] See, e.g., Tilton v. Cowles Publishing Co. (1969), 76 Wash.2d 707 , 459 P.2d 8 , cert. denied 399 U.S. 927 , 90 S.Ct. 2238 , 26 L.Ed.2d 792 (1970) (policeman and fireman running for election to a munici | 1 | 1 |
Messinger v. United Statesgreen2 sentences1974See, e.g., Tilton v. Cowles Publishing Co. (1969), 76 Wash. 2d 707 , 459 P.2d 8 , cert. denied 399 U.S. 927 , 90 S.Ct. 2238 , 26 L.Ed.2d 792 (1970), (policeman and fireman running for election to a municipal health and safety board); Arber v. Stahlin (1968), 10 Mich.App. 181 , 159 N.W.2d 154 , cert. denied, 397 U.S. 924 ; 90 S.Ct. 927 , 25 L.Ed.2d 103 (1970) (republican party volunteer workers and precinct delegates); Rose v. Koch (1967), 278 Minn. 235 , 154 N.W.2d 409 (a university professor who was both a noted author and a former state legislator at the time of publication); Grayson v. Curt 1974NOTES [1] A test was developed for ascertaining the identity of a "public official" within the New York Times standard: "[T]hose among the hierarchy of government employees who have, or appear to the public to have, substantial responsibility for or control over the conduct of public and governmental affairs." Rosenblatt v. Baer (1966), 383 U.S. 75, 85 , 86 S.Ct. 669, 676 , 15 L.Ed.2d 597 . [2] See, e.g., Tilton v. Cowles Publishing Co. (1969), 76 Wash.2d 707 , 459 P.2d 8 , cert. denied 399 U.S. 927 , 90 S.Ct. 2238 , 26 L.Ed.2d 792 (1970) (policeman and fireman running for election to a munici | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Indiana. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Curtis Publishing Co. v. Butts
green
2 sentences1974In a subsequent decision, Curtis Publishing Co. v. Butts (1967), 388 U.S. 130 , 87 S.Ct. 1975 , 18 L.Ed.2d 1094 , the Court extended the New York Times privilege to media comments on matters of public interest concerning “public figures.” While the meaning of the term “public official” has caused the Court little difficulty, 1 the question of who is or who is not a “public figure” has not been fully resolved by the Court. 1974In a subsequent decision, Curtis Publishing Co. v. Butts (1967), 388 U.S. 130 , 87 S.Ct. 1975 , 18 L.Ed.2d 1094 , the Court extended the New York Times privilege to media comments on matters of public interest concerning “public figures.” While the meaning of the term “public official” has caused the Court little difficulty, 1 the question of who is or who is not a “public figure” has not been fully resolved by the Court. | 2 | 1974–1999 |
Aafco Heating & Air Conditioning Co. v. Northwest Publications, Inc.
green
2 sentences1999In his dissent in Aafco, Judge Garrard noted that "at the time the trial court rendered its decision, it was guided only by the plurality opinion of Rosenbloom v. Metromedia, Inc. (1971), 403 U.S. 29 , 91 S.Ct. 1811 , 29 L.Ed.2d 296 , which indicated that application of the New York Times standard would be proper.” Aafco, 162 Ind.App. at 689 , 321 N.E.2d at 591-92 . 1999In his dissent in Aafco, Judge Garrard noted that "at the time the trial court rendered its decision, it was guided only by the plurality opinion of Rosenbloom v. Metromedia, Inc. (1971), 403 U.S. 29 , 91 S.Ct. 1811 , 29 L.Ed.2d 296 , which indicated that application of the New York Times standard would be proper.” Aafco, 162 Ind.App. at 689 , 321 N.E.2d at 591-92 . | 2 | 1991–1999 |
Rosenbloom v. Metromedia, Inc.
red
2 sentences1999The Court disapproved of such an extension on two grounds: (1) “[t]he extension of the New York Times test proposed by the Rosenbloom plurality would abridge this legitimate state interest to a degree that we find unacceptable,” and (2) “it would occasion the additional difficulty of forcing state and federal judges to decide on an ad hoc basis which publications address issues of ‘general or public interest’ and which do not — to determine, in the words of Mr. Justice Marshall, ‘what information is relevant to self-government.’ ” Id. at 346, 94 S.Ct. at 3010 , 41 L.Ed.2d at 809 (quoting Rosen 1999The Court disapproved of such an extension on two grounds: (1) “[t]he extension of the New York Times test proposed by the Rosenbloom plurality would abridge this legitimate state interest to a degree that we find unacceptable,” and (2) “it would occasion the additional difficulty of forcing state and federal judges to decide on an ad hoc basis which publications address issues of ‘general or public interest’ and which do not — to determine, in the words of Mr. Justice Marshall, ‘what information is relevant to self-government.’ ” Id. at 346, 94 S.Ct. at 3010 , 41 L.Ed.2d at 809 (quoting Rosen | 2 | 1974–1999 |
Beckley Newspapers Corp. v. Hanks
green
2 sentences1977Beckley Newspapers v. Hanks, supra, 389 U.S. at 82 , 88 S.Ct. 198 . 1977Beckley Newspapers v. Hanks, supra, 389 U.S. at 82 , 88 S.Ct. 198 . | 2 | 1974–1977 |
Pickering v. Board of Ed. of Township High School Dist. 205, Will Cty.
green
2 sentences2011In Pickering , the Court expressly declined to adopt the New York Times standard as the test to apply to government-employee speech on public matters because of the difficulty in applying a general standard to the “enormous variety of fact situations” in which public employees speak to the dismay of their employers. 391 U.S. at 569 , 88 S.Ct. 1731 . 2011In Pickering , the Court expressly declined to adopt the New York Times standard as the test to apply to government-employee speech on public matters because of the difficulty in applying a general standard to the “enormous variety of fact situations” in which public employees speak to the dismay of their employers. 391 U.S. at 569 , 88 S.Ct. 1731 . | 1 | 2011–2011 |
Herbert v. Lando
green
2 sentences1996"Realistically, some error is inevitable; and the difficulties of separating fact from fiction convinced the Court in New York Times, Butts, Gertz [v. Robert Welch, Inc., 418 U.S. 323 , 94 S.Ct. 2997 , 41 L.Ed.2d 789 (1974)] and similar cases to limit liability to instances where some degree of culpability is present in order to eliminate the risk of undue self-censorship and the suppression of truthful material." - Herbert v. Lando, 441 U.S. 153, 171-172 , 99 S.Ct. 1635, 1646-1647 , 60 L.Ed.2d 115 (1979). "[Elrroneous statement is inevitable in free debate, and . must be protected if the free 1996"Realistically, some error is inevitable; and the difficulties of separating fact from fiction convinced the Court in New York Times, Butts, Gertz [v. Robert Welch, Inc., 418 U.S. 323 , 94 S.Ct. 2997 , 41 L.Ed.2d 789 (1974)] and similar cases to limit liability to instances where some degree of culpability is present in order to eliminate the risk of undue self-censorship and the suppression of truthful material." - Herbert v. Lando, 441 U.S. 153, 171-172 , 99 S.Ct. 1635, 1646-1647 , 60 L.Ed.2d 115 (1979). "[Elrroneous statement is inevitable in free debate, and . must be protected if the free | 1 | 1996–1996 |
Time, Inc. v. Pape
green
2 sentences1996In the area of free speech, such cases are to be anticipated: The statement in this case represents the sort of inaccuracy that is commonplace in the forum of robust debate to which the New York Times rule applies. 401 U.S. at 292, 91 S.Ct. at 640 [citing Time, Inc. v. Pape, 401 U.S. 279 , 91 S.Ct. 633 , 28 LEd.2d 45 (1971)]. 1996In the area of free speech, such cases are to be anticipated: The statement in this case represents the sort of inaccuracy that is commonplace in the forum of robust debate to which the New York Times rule applies. 401 U.S. at 292, 91 S.Ct. at 640 [citing Time, Inc. v. Pape, 401 U.S. 279 , 91 S.Ct. 633 , 28 LEd.2d 45 (1971)]. | 1 | 1996–1996 |
Le Conté Cosmetics, Inc. v. J. B. Williams Co.
green
1 sentence1991Aafco Heating & Air Conditioning Co. v. Northwest Publications, Inc., (1974), 162 Ind.App. 671, 680 , 321 N.E.2d 580, 586 , cert. denied (1975), 424 U.S. 913 , 96 S.Ct. 1112 , 47 L.Ed.2d 318 . | 1 | 1991–1991 |
Aafco Heating & Air Conditioning Co. v. Northwest Publications, Inc.
green
1 sentence1991Aafco Heating & Air Conditioning Co. v. Northwest Publications, Inc., (1974), 162 Ind.App. 671, 680 , 321 N.E.2d 580, 586 , cert. denied (1975), 424 U.S. 913 , 96 S.Ct. 1112 , 47 L.Ed.2d 318 . | 1 | 1991–1991 |
Hotchner v. Castillo-Puche
green
1 sentence1978If the evidence, so considered, measures up to the New York Times standard, the case is one for the jury, and it is error to grant a directed verdict, as the trial judge did in this case.” *565 In Hotchner v. Castillo-Puche, supra, it was stated: “Principles applicable to summary judgment motions generally, are applicable to such motions when made in a defamation action.” 404 F. Supp. at 1050 . | 1 | 1978–1978 |
State Ex Rel. Lyon v. City Council of Augusta
neutral
2 sentences1977Beckley Newspapers v. Hanks, supra, 389 U.S. at 82 , 88 S.Ct. 198 . 1977Beckley Newspapers v. Hanks, supra, 389 U.S. at 82 , 88 S.Ct. 198 . | 1 | 1977–1977 |
Rosenblatt v. Baer
green
2 sentences1974A test was developed for ascertaining the identity of a “public official” within the New York Times standard: “[T]hose among the hierarchy of government employees who have, or appear to the public to have, substantial responsibility for or control over the conduct of public and governmental affairs.” Rosenblatt v. Baer (1966), 383 U.S. 75, 85 , 86 S.Ct. 669, 676 , 15 L.Ed.2d 597 . . 1974A test was developed for ascertaining the identity of a “public official” within the New York Times standard: “[T]hose among the hierarchy of government employees who have, or appear to the public to have, substantial responsibility for or control over the conduct of public and governmental affairs.” Rosenblatt v. Baer (1966), 383 U.S. 75, 85 , 86 S.Ct. 669, 676 , 15 L.Ed.2d 597 . . | 1 | 1974–1974 |
Grayson v. Curtis Publishing Co.
green
2 sentences1974NOTES [1] A test was developed for ascertaining the identity of a "public official" within the New York Times standard: "[T]hose among the hierarchy of government employees who have, or appear to the public to have, substantial responsibility for or control over the conduct of public and governmental affairs." Rosenblatt v. Baer (1966), 383 U.S. 75, 85 , 86 S.Ct. 669, 676 , 15 L.Ed.2d 597 . [2] See, e.g., Tilton v. Cowles Publishing Co. (1969), 76 Wash.2d 707 , 459 P.2d 8 , cert. denied 399 U.S. 927 , 90 S.Ct. 2238 , 26 L.Ed.2d 792 (1970) (policeman and fireman running for election to a munici 1974NOTES [1] A test was developed for ascertaining the identity of a "public official" within the New York Times standard: "[T]hose among the hierarchy of government employees who have, or appear to the public to have, substantial responsibility for or control over the conduct of public and governmental affairs." Rosenblatt v. Baer (1966), 383 U.S. 75, 85 , 86 S.Ct. 669, 676 , 15 L.Ed.2d 597 . [2] See, e.g., Tilton v. Cowles Publishing Co. (1969), 76 Wash.2d 707 , 459 P.2d 8 , cert. denied 399 U.S. 927 , 90 S.Ct. 2238 , 26 L.Ed.2d 792 (1970) (policeman and fireman running for election to a munici | 1 | 1974–1974 |
Miami Herald Publishing Co. v. Tornillo
green
2 sentences1974When the public official or public figure is a minor functionary, or has left the position that put him in the public eye, see Rosenblatt v. Baer, supra , the argument loses all of its force." 403 U.S. at 46 , 91 S.Ct. at 1821 . [6] The United States Supreme Court's recent decision in Miami Herald Publishing Co. v. Tornillo (1974), 418 U.S. 241 , 94 S.Ct. 2831 , 41 L.Ed.2d 730 , which held Florida's right-to-reply statute constitutionally invalid, does not foreclose legislative creation of a limited right of action to compel retraction of libelous statements. 1974When the public official or public figure is a minor functionary, or has left the position that put him in the public eye, see Rosenblatt v. Baer, supra , the argument loses all of its force." 403 U.S. at 46 , 91 S.Ct. at 1821 . [6] The United States Supreme Court's recent decision in Miami Herald Publishing Co. v. Tornillo (1974), 418 U.S. 241 , 94 S.Ct. 2831 , 41 L.Ed.2d 730 , which held Florida's right-to-reply statute constitutionally invalid, does not foreclose legislative creation of a limited right of action to compel retraction of libelous statements. | 1 | 1974–1974 |
Rose v. Koch
green
2 sentences1974NOTES [1] A test was developed for ascertaining the identity of a "public official" within the New York Times standard: "[T]hose among the hierarchy of government employees who have, or appear to the public to have, substantial responsibility for or control over the conduct of public and governmental affairs." Rosenblatt v. Baer (1966), 383 U.S. 75, 85 , 86 S.Ct. 669, 676 , 15 L.Ed.2d 597 . [2] See, e.g., Tilton v. Cowles Publishing Co. (1969), 76 Wash.2d 707 , 459 P.2d 8 , cert. denied 399 U.S. 927 , 90 S.Ct. 2238 , 26 L.Ed.2d 792 (1970) (policeman and fireman running for election to a munici 1974NOTES [1] A test was developed for ascertaining the identity of a "public official" within the New York Times standard: "[T]hose among the hierarchy of government employees who have, or appear to the public to have, substantial responsibility for or control over the conduct of public and governmental affairs." Rosenblatt v. Baer (1966), 383 U.S. 75, 85 , 86 S.Ct. 669, 676 , 15 L.Ed.2d 597 . [2] See, e.g., Tilton v. Cowles Publishing Co. (1969), 76 Wash.2d 707 , 459 P.2d 8 , cert. denied 399 U.S. 927 , 90 S.Ct. 2238 , 26 L.Ed.2d 792 (1970) (policeman and fireman running for election to a munici | 1 | 1974–1974 |
Arber v. Stahlin
neutral
2 sentences1974NOTES [1] A test was developed for ascertaining the identity of a "public official" within the New York Times standard: "[T]hose among the hierarchy of government employees who have, or appear to the public to have, substantial responsibility for or control over the conduct of public and governmental affairs." Rosenblatt v. Baer (1966), 383 U.S. 75, 85 , 86 S.Ct. 669, 676 , 15 L.Ed.2d 597 . [2] See, e.g., Tilton v. Cowles Publishing Co. (1969), 76 Wash.2d 707 , 459 P.2d 8 , cert. denied 399 U.S. 927 , 90 S.Ct. 2238 , 26 L.Ed.2d 792 (1970) (policeman and fireman running for election to a munici 1974NOTES [1] A test was developed for ascertaining the identity of a "public official" within the New York Times standard: "[T]hose among the hierarchy of government employees who have, or appear to the public to have, substantial responsibility for or control over the conduct of public and governmental affairs." Rosenblatt v. Baer (1966), 383 U.S. 75, 85 , 86 S.Ct. 669, 676 , 15 L.Ed.2d 597 . [2] See, e.g., Tilton v. Cowles Publishing Co. (1969), 76 Wash.2d 707 , 459 P.2d 8 , cert. denied 399 U.S. 927 , 90 S.Ct. 2238 , 26 L.Ed.2d 792 (1970) (policeman and fireman running for election to a munici | 1 | 1974–1974 |
Evening News Ass'n v. Arber
green
2 sentences1974See, e.g., Tilton v. Cowles Publishing Co. (1969), 76 Wash. 2d 707 , 459 P.2d 8 , cert. denied 399 U.S. 927 , 90 S.Ct. 2238 , 26 L.Ed.2d 792 (1970), (policeman and fireman running for election to a municipal health and safety board); Arber v. Stahlin (1968), 10 Mich.App. 181 , 159 N.W.2d 154 , cert. denied, 397 U.S. 924 ; 90 S.Ct. 927 , 25 L.Ed.2d 103 (1970) (republican party volunteer workers and precinct delegates); Rose v. Koch (1967), 278 Minn. 235 , 154 N.W.2d 409 (a university professor who was both a noted author and a former state legislator at the time of publication); Grayson v. Curt 1974NOTES [1] A test was developed for ascertaining the identity of a "public official" within the New York Times standard: "[T]hose among the hierarchy of government employees who have, or appear to the public to have, substantial responsibility for or control over the conduct of public and governmental affairs." Rosenblatt v. Baer (1966), 383 U.S. 75, 85 , 86 S.Ct. 669, 676 , 15 L.Ed.2d 597 . [2] See, e.g., Tilton v. Cowles Publishing Co. (1969), 76 Wash.2d 707 , 459 P.2d 8 , cert. denied 399 U.S. 927 , 90 S.Ct. 2238 , 26 L.Ed.2d 792 (1970) (policeman and fireman running for election to a munici | 1 | 1974–1974 |
Gordon v. Spunt
green
2 sentences1974See, e.g., Tilton v. Cowles Publishing Co. (1969), 76 Wash. 2d 707 , 459 P.2d 8 , cert. denied 399 U.S. 927 , 90 S.Ct. 2238 , 26 L.Ed.2d 792 (1970), (policeman and fireman running for election to a municipal health and safety board); Arber v. Stahlin (1968), 10 Mich.App. 181 , 159 N.W.2d 154 , cert. denied, 397 U.S. 924 ; 90 S.Ct. 927 , 25 L.Ed.2d 103 (1970) (republican party volunteer workers and precinct delegates); Rose v. Koch (1967), 278 Minn. 235 , 154 N.W.2d 409 (a university professor who was both a noted author and a former state legislator at the time of publication); Grayson v. Curt 1974NOTES [1] A test was developed for ascertaining the identity of a "public official" within the New York Times standard: "[T]hose among the hierarchy of government employees who have, or appear to the public to have, substantial responsibility for or control over the conduct of public and governmental affairs." Rosenblatt v. Baer (1966), 383 U.S. 75, 85 , 86 S.Ct. 669, 676 , 15 L.Ed.2d 597 . [2] See, e.g., Tilton v. Cowles Publishing Co. (1969), 76 Wash.2d 707 , 459 P.2d 8 , cert. denied 399 U.S. 927 , 90 S.Ct. 2238 , 26 L.Ed.2d 792 (1970) (policeman and fireman running for election to a munici | 1 | 1974–1974 |
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.