Masson v. New Yorker Magazine
Masson v. New Yorker Magazine is a significant legal case centered around a libel suit filed by psychoanalyst Jeffrey Masson against journalist Janet Malcolm and The New Yorker magazine. The controversy arose from Malcolm's critical articles about Masson, which he claimed contained fabricated quotations attributed to him. As a public figure, Masson was required to demonstrate actual malice in his case, which involves proving that the defendants acted with knowledge of the falsity of their statements or with reckless disregard for the truth. Initially, lower federal courts dismissed his claim, arguing that the interpretations presented did not meet this stringent standard. However, the Supreme Court intervened, ruling by a 7-2 vote that any significant alteration of a person's words could indicate knowledge of falsity if it materially changed the meaning of the statements. This decision emphasized the importance of accuracy in journalism, particularly regarding the use of quotation marks. The upcoming jury trial was tasked with determining if the alleged alterations in Malcolm's portrayal sufficiently met the legal requirements established by prior cases regarding libel. This case has had lasting implications for the relationship between media freedom and the protection of individual reputations.
Masson v. New Yorker Magazine
Date: January 14, 1991
Citation: 501 U.S. 496
Issues: Libel; freedom of the press
Significance: The Supreme Court held that the First Amendment allows for public persons to win libel suits against journalists who deliberately distort the meaning of their statements.
Janet Malcolm, a contributor to The New Yorker magazine, published a two-part article that was highly critical of psychoanalyst Jeffrey Masson, a former director of the Sigmund Freud Archives. In a libel suit against Malcolm and the magazine, Masson claimed that many of the statements attributed to him in quotation marks were fabrications. Because he was a public person, New York Times Co. v. Sullivan (1964) was applicable to the suit, and therefore, Masson had the burden of proving actual malice, which meant either knowledge of falsity or a reckless disregard for truthful reporting. The lower federal courts dismissed the suit, holding that interpretations of actual statements did not constitute actual malice.
By a 7-2 vote, the Supreme Court rejected the lower courts’ judgment and remanded the case for a jury trial. Justice Anthony M. Kennedy’s opinion for the majority held that a “deliberate alteration of words” in a statement constitutes a knowledge of falsity if it materially changes “the meaning conveyed by the statement.” In the upcoming trial, therefore, the jury would have the task of deciding whether the meaning of Masson’s statements had been sufficiently altered to satisfy the Sullivan standard. The Masson decision provided notice to writers and publishers to be very careful when using quotation marks that appear to denote a person’s actual words.