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11 Minnesota opinions name it 2 courts 1967–2023 1 in the last five years
The cases below were cited by Minnesota 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 sentences2023And the Court confirmed that Gertz had “repudiated” the view that the “New York Times privilege should be extended to falsehoods defamatory of private persons whenever the statements concern matters of general or public interest.” D-6 Id. at 454; see also Gertz, 418 U.S. at 346 (rejecting “[t]he ‘public or general interest’ test for determining the applicability of the New York Times standard” because that test “inadequately serves both of the competing values at stake”); cf. Waldbaum v. Fairchild Pub., Inc., 627 F.2d 1287, 1296 (D.C. 2023And the Court confirmed that Gertz had “repudiated” the view that the “New York Times privilege should be extended to falsehoods defamatory of private persons whenever the statements concern matters of general or public interest.” D-6 Id. at 454; see also Gertz, 418 U.S. at 346 (rejecting “[t]he ‘public or general interest’ test for determining the applicability of the New York Times standard” because that test “inadequately serves both of the competing values at stake”); cf. Waldbaum v. Fairchild Pub., Inc., 627 F.2d 1287, 1296 (D.C. | 4 | 5 |
New York Times Co. v. Sullivangreen2 sentences1991The Supreme Court, in New York Times , recognized Minnesota as a state that followed a rule similar to the New York Times rule and cited Friedell v. Blakely Printing Co., 163 Minn. 226, 230 , 203 N.W. 974 , 975 (1925). 376 U.S. at 280, n. 20 , 84 S.Ct. at 726, n. 20 . 1991The Supreme Court, in New York Times , recognized Minnesota as a state that followed a rule similar to the New York Times rule and cited Friedell v. Blakely Printing Co., 163 Minn. 226, 230 , 203 N.W. 974 , 975 (1925). 376 U.S. at 280, n. 20 , 84 S.Ct. at 726, n. 20 . | 2 | 3 |
Rosenblatt v. Baergreen2 sentences1985The New York Times rule was obliged to yield only to preserve "'our basic concept of the essential dignity and worth of every human being.'" See Gertz, 418 U.S. at 341 , 94 S.Ct. at 3008 quoting Rosenblatt v. Baer, 383 U.S. 75, 92 , 86 S.Ct. 669, 679 , 15 L.Ed.2d 597 (1966) (Stewart, J., concurring). 1985The New York Times rule was obliged to yield only to preserve "'our basic concept of the essential dignity and worth of every human being.'" See Gertz, 418 U.S. at 341 , 94 S.Ct. at 3008 quoting Rosenblatt v. Baer, 383 U.S. 75, 92 , 86 S.Ct. 669, 679 , 15 L.Ed.2d 597 (1966) (Stewart, J., concurring). | 1 | 2 |
Eric Waldbaum v. Fairchild Publications, Incgreen2 sentences2023And the Court confirmed that Gertz had “repudiated” the view that the “New York Times privilege should be extended to falsehoods defamatory of private persons whenever the statements concern matters of general or public interest.” D-6 Id. at 454; see also Gertz, 418 U.S. at 346 (rejecting “[t]he ‘public or general interest’ test for determining the applicability of the New York Times standard” because that test “inadequately serves both of the competing values at stake”); cf. Waldbaum v. Fairchild Pub., Inc., 627 F.2d 1287, 1296 (D.C. 2023And the Court confirmed that Gertz had “repudiated” the view that the “New York Times privilege should be extended to falsehoods defamatory of private persons whenever the statements concern matters of general or public interest.” D-6 Id. at 454; see also Gertz, 418 U.S. at 346 (rejecting “[t]he ‘public or general interest’ test for determining the applicability of the New York Times standard” because that test “inadequately serves both of the competing values at stake”); cf. Waldbaum v. Fairchild Pub., Inc., 627 F.2d 1287, 1296 (D.C. | 1 | 1 |
Time, Inc. v. Firestonegreen2 sentences2023And the Court confirmed that Gertz had “repudiated” the view that the “New York Times privilege should be extended to falsehoods defamatory of private persons whenever the statements concern matters of general or public interest.” D-6 Id. at 454; see also Gertz, 418 U.S. at 346 (rejecting “[t]he ‘public or general interest’ test for determining the applicability of the New York Times standard” because that test “inadequately serves both of the competing values at stake”); cf. Waldbaum v. Fairchild Pub., Inc., 627 F.2d 1287, 1296 (D.C. 2023And the Court confirmed that Gertz had “repudiated” the view that the “New York Times privilege should be extended to falsehoods defamatory of private persons whenever the statements concern matters of general or public interest.” D-6 Id. at 454; see also Gertz, 418 U.S. at 346 (rejecting “[t]he ‘public or general interest’ test for determining the applicability of the New York Times standard” because that test “inadequately serves both of the competing values at stake”); cf. Waldbaum v. Fairchild Pub., Inc., 627 F.2d 1287, 1296 (D.C. | 1 | 1 |
Stuempges v. Parke, Davis & Co.green1 sentence2009Stuempges, 297 N.W.2d at 258 (stating that the New York Times standard “was fashioned as an exception to the common law rule to permit the ... media to perform their function ... without undue fear of defamation liability”). | 1 | 1 |
Rutt v. Bethlehems' Globe Publishing Co.green2 sentences1991The following cases from other jurisdictions have addressed the issue and concluded that law enforcement officers at various levels are public officials for purposes of the New York Times rule: Time, Inc. v. Pape, 401 U.S. 279 , 91 S.Ct. 633 , 28 L.Ed.2d 45 (1971) (police detective was public official); Ethridge v. North Mississippi Communications, Inc., 460 F.Supp. 347 (N.D.Miss.1978) (applying Mississippi law) (city police *523 officer was public official even though he worked undercover and was not widely known); Smith v. Russell, 456 So.2d 462 (Fla.1984), cert. denied, 470 U.S. 1027 , 105 1991The following cases from other jurisdictions have addressed the issue and concluded that law enforcement officers at various levels are public officials for purposes of the New York Times rule: Time, Inc. v. Pape, 401 U.S. 279 , 91 S.Ct. 633 , 28 L.Ed.2d 45 (1971) (police detective was public official); Ethridge v. North Mississippi Communications, Inc., 460 F.Supp. 347 (N.D.Miss.1978) (applying Mississippi law) (city police *523 officer was public official even though he worked undercover and was not widely known); Smith v. Russell, 456 So.2d 462 (Fla.1984), cert. denied, 470 U.S. 1027 , 105 | 1 | 1 |
Mahnke v. Northwest Publications, Inc.green2 sentences1991See 280 Minn. at 349-51 , 160 N.W.2d at 14-15 (approving jury instructions). 1991See 280 Minn. at 349-51 , 160 N.W.2d at 14-15 (approving jury instructions). | 1 | 1 |
NAACP v. Moodygreen1 sentence1991The following cases from other jurisdictions have addressed the issue and concluded that law enforcement officers at various levels are public officials for purposes of the New York Times rule: Time, Inc. v. Pape, 401 U.S. 279 , 91 S.Ct. 633 , 28 L.Ed.2d 45 (1971) (police detective was public official); Ethridge v. North Mississippi Communications, Inc., 460 F.Supp. 347 (N.D.Miss.1978) (applying Mississippi law) (city police *523 officer was public official even though he worked undercover and was not widely known); Smith v. Russell, 456 So.2d 462 (Fla.1984), cert. denied, 470 U.S. 1027 , 105 | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
Pickering v. Board of Ed. of Township High School Dist. 205, Will Cty.green2 sentences1987See Rosenblatt v. Baer, 383 U.S. 75 , 86 S.Ct. 669 , 15 L.Ed.2d 597 (1966) (extended scope of “public official” to supervisor of county ski area); Pickering v. Board of Education of Township High School District 205, Will County, Illinois, 391 U.S. 563 , 88 S.Ct. 1731 , 20 L.Ed.2d 811 (1968) (holding that criticism of school system funding practices is an issue of public concern); St. 1987See Rosenblatt v. Baer, 383 U.S. 75 , 86 S.Ct. 669 , 15 L.Ed.2d 597 (1966) (extended scope of “public official” to supervisor of county ski area); Pickering v. Board of Education of Township High School District 205, Will County, Illinois, 391 U.S. 563 , 88 S.Ct. 1731 , 20 L.Ed.2d 811 (1968) (holding that criticism of school system funding practices is an issue of public concern); St. | 1 | 1 |
| Case | Cited | Years |
|---|---|---|
Time, Inc. v. Hill
green
2 sentences1968At the outset of his opinion, Mr. Justice Harlan noted the need for— “* * * some further exploration and clarification of the relationship between libel law and the freedom of speech and press, lest the New York Times rule become a talisman which gives the press constitutionally adequate protection only in a limited field, or, what would be equally unfortunate, one which goes far to immunize the press from having to make just reparation for the infliction of needless injury upon honor and reputation through false publication.” See, Time, Inc. v. Hill, 385 U. S. 374 , 87 S. Ct. 534 , 17 L. ed. 1968At the outset of his opinion, Mr. Justice Harlan noted the need for— “* * * some further exploration and clarification of the relationship between libel law and the freedom of speech and press, lest the New York Times rule become a talisman which gives the press constitutionally adequate protection only in a limited field, or, what would be equally unfortunate, one which goes far to immunize the press from having to make just reparation for the infliction of needless injury upon honor and reputation through false publication.” See, Time, Inc. v. Hill, 385 U. S. 374 , 87 S. Ct. 534 , 17 L. ed. | 3 | 1967–1987 |
Curtis Publishing Co. v. Butts
green
2 sentences1987The New York Times standard was subsequently applied to cases involving “public figures” who were not government officials when the statements related to issues of public concern, Curtis Publishing Co. v. Butts, 388 U.S. 130 , 87 S.Ct. 1975 , 18 L.Ed.2d 1094 (1967), and in Rosenbloom v. Metromedia, Inc., 403 U.S. 29 , 91 S.Ct. 1811 , 29 L.Ed.2d 296 (1971), the Supreme Court extended the New York Times rule to all “communication involving matters of public or general concern without regard to whether the persons involved are famous or anonymous.” Id. at 44 , 91 S.Ct. at 1820 . 1 Rosenbloom , a 1987The New York Times standard was subsequently applied to cases involving “public figures” who were not government officials when the statements related to issues of public concern, Curtis Publishing Co. v. Butts, 388 U.S. 130 , 87 S.Ct. 1975 , 18 L.Ed.2d 1094 (1967), and in Rosenbloom v. Metromedia, Inc., 403 U.S. 29 , 91 S.Ct. 1811 , 29 L.Ed.2d 296 (1971), the Supreme Court extended the New York Times rule to all “communication involving matters of public or general concern without regard to whether the persons involved are famous or anonymous.” Id. at 44 , 91 S.Ct. at 1820 . 1 Rosenbloom , a | 3 | 1967–1987 |
Rosenbloom v. Metromedia, Inc.
red
2 sentences1987The New York Times standard was subsequently applied to cases involving “public figures” who were not government officials when the statements related to issues of public concern, Curtis Publishing Co. v. Butts, 388 U.S. 130 , 87 S.Ct. 1975 , 18 L.Ed.2d 1094 (1967), and in Rosenbloom v. Metromedia, Inc., 403 U.S. 29 , 91 S.Ct. 1811 , 29 L.Ed.2d 296 (1971), the Supreme Court extended the New York Times rule to all “communication involving matters of public or general concern without regard to whether the persons involved are famous or anonymous.” Id. at 44 , 91 S.Ct. at 1820 . 1 Rosenbloom , a 1987The New York Times standard was subsequently applied to cases involving “public figures” who were not government officials when the statements related to issues of public concern, Curtis Publishing Co. v. Butts, 388 U.S. 130 , 87 S.Ct. 1975 , 18 L.Ed.2d 1094 (1967), and in Rosenbloom v. Metromedia, Inc., 403 U.S. 29 , 91 S.Ct. 1811 , 29 L.Ed.2d 296 (1971), the Supreme Court extended the New York Times rule to all “communication involving matters of public or general concern without regard to whether the persons involved are famous or anonymous.” Id. at 44 , 91 S.Ct. at 1820 . 1 Rosenbloom , a | 2 | 1985–1987 |
Ethridge v. North Mississippi Communications, Inc.
green
1 sentence1991The following cases from other jurisdictions have addressed the issue and concluded that law enforcement officers at various levels are public officials for purposes of the New York Times rule: Time, Inc. v. Pape, 401 U.S. 279 , 91 S.Ct. 633 , 28 L.Ed.2d 45 (1971) (police detective was public official); Ethridge v. North Mississippi Communications, Inc., 460 F.Supp. 347 (N.D.Miss.1978) (applying Mississippi law) (city police *523 officer was public official even though he worked undercover and was not widely known); Smith v. Russell, 456 So.2d 462 (Fla.1984), cert. denied, 470 U.S. 1027 , 105 | 1 | 1991–1991 |
Orr v. Lynch
green
2 sentences1991The following cases from other jurisdictions have addressed the issue and concluded that law enforcement officers at various levels are public officials for purposes of the New York Times rule: Time, Inc. v. Pape, 401 U.S. 279 , 91 S.Ct. 633 , 28 L.Ed.2d 45 (1971) (police detective was public official); Ethridge v. North Mississippi Communications, Inc., 460 F.Supp. 347 (N.D.Miss.1978) (applying Mississippi law) (city police *523 officer was public official even though he worked undercover and was not widely known); Smith v. Russell, 456 So.2d 462 (Fla.1984), cert. denied, 470 U.S. 1027 , 105 1991The following cases from other jurisdictions have addressed the issue and concluded that law enforcement officers at various levels are public officials for purposes of the New York Times rule: Time, Inc. v. Pape, 401 U.S. 279 , 91 S.Ct. 633 , 28 L.Ed.2d 45 (1971) (police detective was public official); Ethridge v. North Mississippi Communications, Inc., 460 F.Supp. 347 (N.D.Miss.1978) (applying Mississippi law) (city police *523 officer was public official even though he worked undercover and was not widely known); Smith v. Russell, 456 So.2d 462 (Fla.1984), cert. denied, 470 U.S. 1027 , 105 | 1 | 1991–1991 |
Times Herald Printing Co. v. Bessent
green
1 sentence1991The following cases from other jurisdictions have addressed the issue and concluded that law enforcement officers at various levels are public officials for purposes of the New York Times rule: Time, Inc. v. Pape, 401 U.S. 279 , 91 S.Ct. 633 , 28 L.Ed.2d 45 (1971) (police detective was public official); Ethridge v. North Mississippi Communications, Inc., 460 F.Supp. 347 (N.D.Miss.1978) (applying Mississippi law) (city police *523 officer was public official even though he worked undercover and was not widely known); Smith v. Russell, 456 So.2d 462 (Fla.1984), cert. denied, 470 U.S. 1027 , 105 | 1 | 1991–1991 |
Friedell v. Blakely Printing Co.
green
1 sentence1991The Supreme Court, in New York Times , recognized Minnesota as a state that followed a rule similar to the New York Times rule and cited Friedell v. Blakely Printing Co., 163 Minn. 226, 230 , 203 N.W. 974 , 975 (1925). 376 U.S. at 280, n. 20 , 84 S.Ct. at 726, n. 20 . | 1 | 1991–1991 |
Shipley v. Knoxville Journal Corp.
green
1 sentence1991The following cases from other jurisdictions have addressed the issue and concluded that law enforcement officers at various levels are public officials for purposes of the New York Times rule: Time, Inc. v. Pape, 401 U.S. 279 , 91 S.Ct. 633 , 28 L.Ed.2d 45 (1971) (police detective was public official); Ethridge v. North Mississippi Communications, Inc., 460 F.Supp. 347 (N.D.Miss.1978) (applying Mississippi law) (city police *523 officer was public official even though he worked undercover and was not widely known); Smith v. Russell, 456 So.2d 462 (Fla.1984), cert. denied, 470 U.S. 1027 , 105 | 1 | 1991–1991 |
Times-Mirror Co. v. Harden
green
1 sentence1991The following cases from other jurisdictions have addressed the issue and concluded that law enforcement officers at various levels are public officials for purposes of the New York Times rule: Time, Inc. v. Pape, 401 U.S. 279 , 91 S.Ct. 633 , 28 L.Ed.2d 45 (1971) (police detective was public official); Ethridge v. North Mississippi Communications, Inc., 460 F.Supp. 347 (N.D.Miss.1978) (applying Mississippi law) (city police *523 officer was public official even though he worked undercover and was not widely known); Smith v. Russell, 456 So.2d 462 (Fla.1984), cert. denied, 470 U.S. 1027 , 105 | 1 | 1991–1991 |
Newson v. Henry
green
1 sentence1991The following cases from other jurisdictions have addressed the issue and concluded that law enforcement officers at various levels are public officials for purposes of the New York Times rule: Time, Inc. v. Pape, 401 U.S. 279 , 91 S.Ct. 633 , 28 L.Ed.2d 45 (1971) (police detective was public official); Ethridge v. North Mississippi Communications, Inc., 460 F.Supp. 347 (N.D.Miss.1978) (applying Mississippi law) (city police *523 officer was public official even though he worked undercover and was not widely known); Smith v. Russell, 456 So.2d 462 (Fla.1984), cert. denied, 470 U.S. 1027 , 105 | 1 | 1991–1991 |
Romero v. ABBEVILLE BROADCASTING SERVICE
green
1 sentence1991The following cases from other jurisdictions have addressed the issue and concluded that law enforcement officers at various levels are public officials for purposes of the New York Times rule: Time, Inc. v. Pape, 401 U.S. 279 , 91 S.Ct. 633 , 28 L.Ed.2d 45 (1971) (police detective was public official); Ethridge v. North Mississippi Communications, Inc., 460 F.Supp. 347 (N.D.Miss.1978) (applying Mississippi law) (city police *523 officer was public official even though he worked undercover and was not widely known); Smith v. Russell, 456 So.2d 462 (Fla.1984), cert. denied, 470 U.S. 1027 , 105 | 1 | 1991–1991 |
Time, Inc. v. Pape
green
2 sentences1991The following cases from other jurisdictions have addressed the issue and concluded that law enforcement officers at various levels are public officials for purposes of the New York Times rule: Time, Inc. v. Pape, 401 U.S. 279 , 91 S.Ct. 633 , 28 L.Ed.2d 45 (1971) (police detective was public official); Ethridge v. North Mississippi Communications, Inc., 460 F.Supp. 347 (N.D.Miss.1978) (applying Mississippi law) (city police *523 officer was public official even though he worked undercover and was not widely known); Smith v. Russell, 456 So.2d 462 (Fla.1984), cert. denied, 470 U.S. 1027 , 105 1991The following cases from other jurisdictions have addressed the issue and concluded that law enforcement officers at various levels are public officials for purposes of the New York Times rule: Time, Inc. v. Pape, 401 U.S. 279 , 91 S.Ct. 633 , 28 L.Ed.2d 45 (1971) (police detective was public official); Ethridge v. North Mississippi Communications, Inc., 460 F.Supp. 347 (N.D.Miss.1978) (applying Mississippi law) (city police *523 officer was public official even though he worked undercover and was not widely known); Smith v. Russell, 456 So.2d 462 (Fla.1984), cert. denied, 470 U.S. 1027 , 105 | 1 | 1991–1991 |
Smith v. Russell
green
1 sentence1991The following cases from other jurisdictions have addressed the issue and concluded that law enforcement officers at various levels are public officials for purposes of the New York Times rule: Time, Inc. v. Pape, 401 U.S. 279 , 91 S.Ct. 633 , 28 L.Ed.2d 45 (1971) (police detective was public official); Ethridge v. North Mississippi Communications, Inc., 460 F.Supp. 347 (N.D.Miss.1978) (applying Mississippi law) (city police *523 officer was public official even though he worked undercover and was not widely known); Smith v. Russell, 456 So.2d 462 (Fla.1984), cert. denied, 470 U.S. 1027 , 105 | 1 | 1991–1991 |
Dunlap v. Philadelphia Newspapers, Inc.
green
2 sentences1991The following cases from other jurisdictions have addressed the issue and concluded that law enforcement officers at various levels are public officials for purposes of the New York Times rule: Time, Inc. v. Pape, 401 U.S. 279 , 91 S.Ct. 633 , 28 L.Ed.2d 45 (1971) (police detective was public official); Ethridge v. North Mississippi Communications, Inc., 460 F.Supp. 347 (N.D.Miss.1978) (applying Mississippi law) (city police *523 officer was public official even though he worked undercover and was not widely known); Smith v. Russell, 456 So.2d 462 (Fla.1984), cert. denied, 470 U.S. 1027 , 105 1991The following cases from other jurisdictions have addressed the issue and concluded that law enforcement officers at various levels are public officials for purposes of the New York Times rule: Time, Inc. v. Pape, 401 U.S. 279 , 91 S.Ct. 633 , 28 L.Ed.2d 45 (1971) (police detective was public official); Ethridge v. North Mississippi Communications, Inc., 460 F.Supp. 347 (N.D.Miss.1978) (applying Mississippi law) (city police *523 officer was public official even though he worked undercover and was not widely known); Smith v. Russell, 456 So.2d 462 (Fla.1984), cert. denied, 470 U.S. 1027 , 105 | 1 | 1991–1991 |
Thomas v. Arn
green
1 sentence1991The following cases from other jurisdictions have addressed the issue and concluded that law enforcement officers at various levels are public officials for purposes of the New York Times rule: Time, Inc. v. Pape, 401 U.S. 279 , 91 S.Ct. 633 , 28 L.Ed.2d 45 (1971) (police detective was public official); Ethridge v. North Mississippi Communications, Inc., 460 F.Supp. 347 (N.D.Miss.1978) (applying Mississippi law) (city police *523 officer was public official even though he worked undercover and was not widely known); Smith v. Russell, 456 So.2d 462 (Fla.1984), cert. denied, 470 U.S. 1027 , 105 | 1 | 1991–1991 |
Smith v. Russell
green
1 sentence1991The following cases from other jurisdictions have addressed the issue and concluded that law enforcement officers at various levels are public officials for purposes of the New York Times rule: Time, Inc. v. Pape, 401 U.S. 279 , 91 S.Ct. 633 , 28 L.Ed.2d 45 (1971) (police detective was public official); Ethridge v. North Mississippi Communications, Inc., 460 F.Supp. 347 (N.D.Miss.1978) (applying Mississippi law) (city police *523 officer was public official even though he worked undercover and was not widely known); Smith v. Russell, 456 So.2d 462 (Fla.1984), cert. denied, 470 U.S. 1027 , 105 | 1 | 1991–1991 |
National Broadcasting Co. v. Herman
green
1 sentence1991The following cases from other jurisdictions have addressed the issue and concluded that law enforcement officers at various levels are public officials for purposes of the New York Times rule: Time, Inc. v. Pape, 401 U.S. 279 , 91 S.Ct. 633 , 28 L.Ed.2d 45 (1971) (police detective was public official); Ethridge v. North Mississippi Communications, Inc., 460 F.Supp. 347 (N.D.Miss.1978) (applying Mississippi law) (city police *523 officer was public official even though he worked undercover and was not widely known); Smith v. Russell, 456 So.2d 462 (Fla.1984), cert. denied, 470 U.S. 1027 , 105 | 1 | 1991–1991 |
Murphy v. Acito
green
1 sentence1991The following cases from other jurisdictions have addressed the issue and concluded that law enforcement officers at various levels are public officials for purposes of the New York Times rule: Time, Inc. v. Pape, 401 U.S. 279 , 91 S.Ct. 633 , 28 L.Ed.2d 45 (1971) (police detective was public official); Ethridge v. North Mississippi Communications, Inc., 460 F.Supp. 347 (N.D.Miss.1978) (applying Mississippi law) (city police *523 officer was public official even though he worked undercover and was not widely known); Smith v. Russell, 456 So.2d 462 (Fla.1984), cert. denied, 470 U.S. 1027 , 105 | 1 | 1991–1991 |
Orr v. Lynch
green
2 sentences1991The following cases from other jurisdictions have addressed the issue and concluded that law enforcement officers at various levels are public officials for purposes of the New York Times rule: Time, Inc. v. Pape, 401 U.S. 279 , 91 S.Ct. 633 , 28 L.Ed.2d 45 (1971) (police detective was public official); Ethridge v. North Mississippi Communications, Inc., 460 F.Supp. 347 (N.D.Miss.1978) (applying Mississippi law) (city police *523 officer was public official even though he worked undercover and was not widely known); Smith v. Russell, 456 So.2d 462 (Fla.1984), cert. denied, 470 U.S. 1027 , 105 1991The following cases from other jurisdictions have addressed the issue and concluded that law enforcement officers at various levels are public officials for purposes of the New York Times rule: Time, Inc. v. Pape, 401 U.S. 279 , 91 S.Ct. 633 , 28 L.Ed.2d 45 (1971) (police detective was public official); Ethridge v. North Mississippi Communications, Inc., 460 F.Supp. 347 (N.D.Miss.1978) (applying Mississippi law) (city police *523 officer was public official even though he worked undercover and was not widely known); Smith v. Russell, 456 So.2d 462 (Fla.1984), cert. denied, 470 U.S. 1027 , 105 | 1 | 1991–1991 |
Rose v. Koch
green
1 sentence1987Id. (citing Time, Inc. v. Hill, 385 U.S. 374 , 87 S.Ct. 534 , 17 L.Ed.2d 456 (1967)). | 1 | 1987–1987 |
| United States v. Coleman green | 1 | 1968–1968 |
| Garrison v. Louisiana green | 1 | 1968–1968 |
| Goldwater v. Ginzburg green | 1 | 1968–1968 |
| Smith v. California green | 1 | 1967–1967 |
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.