York Times rule (Minnesota) · Go Syfert
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York Times rule in Minnesota

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.

Followed or applied (9)

CaseFollowedCited
Gertz v. Robert Welch, Inc.green
scotus · 1974 · cited in 5 Minnesota opinions naming this issue, 1979–2023
2 sentences

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.

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.

45
New York Times Co. v. Sullivangreen
scotus · 1964 · cited in 3 Minnesota opinions naming this issue, 1968–1991
2 sentences

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 .

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 .

23
Rosenblatt v. Baergreen
scotus · 1966 · cited in 2 Minnesota opinions naming this issue, 1985–1987
2 sentences

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).

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).

12
Eric Waldbaum v. Fairchild Publications, Incgreen
cadc · 1980 · cited in 1 Minnesota opinions naming this issue, 2023–2023
2 sentences

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.

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.

11
Time, Inc. v. Firestonegreen
scotus · 1976 · cited in 1 Minnesota opinions naming this issue, 2023–2023
2 sentences

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.

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.

11
Stuempges v. Parke, Davis & Co.green
minn · 1980 · cited in 1 Minnesota opinions naming this issue, 2009–2009
1 sentence

2009Stuempges, 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”).

11
Rutt v. Bethlehems' Globe Publishing Co.green
pa · 1984 · cited in 1 Minnesota opinions naming this issue, 1991–1991
2 sentences

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

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

11
Mahnke v. Northwest Publications, Inc.green
minn · 1968 · cited in 1 Minnesota opinions naming this issue, 1991–1991
2 sentences

1991See 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).

11
NAACP v. Moodygreen
miss · 1977 · cited in 1 Minnesota opinions naming this issue, 1991–1991
1 sentence

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

11

Distinguished, questioned or overruled (1)

CaseNegativeCited
Pickering v. Board of Ed. of Township High School Dist. 205, Will Cty.green
scotus · 1968 · cited in 1 Minnesota opinions naming this issue, 1987–1987
2 sentences

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.

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.

11

Also cited on this issue (24)

CaseCitedYears
Time, Inc. v. Hill green
scotus · 1967
2 sentences

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.

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.

31967–1987
Curtis Publishing Co. v. Butts green
scotus · 1967
2 sentences

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

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

31967–1987
Rosenbloom v. Metromedia, Inc. red
scotus · 1971
2 sentences

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

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

21985–1987
Ethridge v. North Mississippi Communications, Inc. green
msnd · 1978
1 sentence

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

11991–1991
Orr v. Lynch green
nyappdiv · 1978
2 sentences

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

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

11991–1991
Times Herald Printing Co. v. Bessent green
texapp · 1980
1 sentence

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

11991–1991
Friedell v. Blakely Printing Co. green
· 1925
1 sentence

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 .

11991–1991
Shipley v. Knoxville Journal Corp. green
tennctapp · 1984
1 sentence

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

11991–1991
Times-Mirror Co. v. Harden green
texapp · 1982
1 sentence

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

11991–1991
Newson v. Henry green
miss · 1983
1 sentence

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

11991–1991
Romero v. ABBEVILLE BROADCASTING SERVICE green
lactapp · 1982
1 sentence

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

11991–1991
Time, Inc. v. Pape green
scotus · 1971
2 sentences

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

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

11991–1991
Smith v. Russell green
fla · 1984
1 sentence

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

11991–1991
Dunlap v. Philadelphia Newspapers, Inc. green
pa · 1982
2 sentences

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

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

11991–1991
Thomas v. Arn green
scotus · 1985
1 sentence

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

11991–1991
Smith v. Russell green
scotus · 1985
1 sentence

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

11991–1991
National Broadcasting Co. v. Herman green
scotus · 1985
1 sentence

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

11991–1991
Murphy v. Acito green
ny · 1978
1 sentence

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

11991–1991
Orr v. Lynch green
ny · 1978
2 sentences

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

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

11991–1991
Rose v. Koch green
minn · 1967
1 sentence

1987Id. (citing Time, Inc. v. Hill, 385 U.S. 374 , 87 S.Ct. 534 , 17 L.Ed.2d 456 (1967)).

11987–1987
United States v. Coleman green
scotus · 1968
11968–1968
Garrison v. Louisiana green
scotus · 1964
11968–1968
Goldwater v. Ginzburg green
nysd · 1966
11968–1968
Smith v. California green
scotus · 1960
11967–1967

Where else courts name it

CA 45 (1969–2016) TX 32 (1975–2019) IL 30 (1968–2019) LA 23 (1966–2017) FL 22 (1969–2010) MD 20 (1970–2016) NY 19 (1964–2009) PA 18 (1971–2015) NJ 16 (1965–1995) OH 15 (1974–2021) MA 14 (1973–2009) SC 14 (1980–2021) AZ 14 (1966–2021) IN 11 (1970–2023) IA 11 (1979–2014) TN 11 (1978–2019) WA 11 (1967–2025) MN 11 (1967–2023) MI 9 (1969–2022) OK 8 (1973–2000) VA 8 (1972–2024) WI 8 (1966–2024) MS 8 (1967–2002) NC 7 (1980–2020) CO 7 (1975–2012) DC 7 (1979–2023) MO 6 (1972–1991) OR 5 (1977–2022) VT 5 (1977–1992) NH 5 (1967–2019) MT 5 (1978–2025) KS 5 (1975–1983) ID 4 (1990–2016) GA 4 (1979–2025) HI 4 (1967–1983) RI 4 (1980–1995) ME 3 (1978–1986) WY 3 (1980–1992) CT 3 (1975–2002) AR 3 (1975–1983) KY 3 (1989–2005) NM 3 (1982–2012) WV 3 (1984–1992) PR 2 (1996–2004) AL 2 (2003–2004) NE 2 (1985–1993) AK 2 (1971–1982) UT 2 (1983–1988) SD 2 (1969–1993)

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.

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