Hustler Magazine, Inc. v. Falwell, 485 US 46 (1988)
US District Court
Jerry Falwell sued Larry Flynt and his publication, Hustler Magazine, for torts of libel and intentional infliction of emotion distress after Hustler published a parody of a Compari (liquor) ad that implied Falwell had incestuous relations with his mother during a drunken encounter in an outhouse.
Flynt was found not guilty of libel, but guilty on the charge of intentional infliction of emotional distress.
The US District Court court incorrectly allowed a civil jury to award Jerry Falwell a total of $200,000 in compensatory and punitive damages for intentional infliction of emotional distress, under the "actual malice" standard established in New York Times v. Sullivan, 376 US 254 (1964).
US Court of Appeals for the Fourth Circuit
The Fourth Circuit affirmed the District Court decision, then denied Hustler a rehearing challenging the verdict's constitutionality in light of New York Times v. Sullivan.
US Supreme Court
The US Supreme Court held that "intentional infliction of emotional distress" could not stand on its own once the defendant was found not guilty of libel (or any defamation) because it would set a dangerous precedent that would have a chilling effect on the First Amendment exercise of free speech.
The Supreme Court reversed the lower court decisions and vacated the jury award.
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