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Hustler Magazine, Inc. v. Falwell, 485 US 46 (1988)

The jury in US District Court made an error in awarding Falwell damages for intentional infliction of emotional distress after finding Flynt and Hustler not guilty of libel. The Supreme Court held that a public figure can't collect monetary damages on the basis intentional infliction of emotional distress alone. The concept of "actual malice," established in New York Times v. Sullivan, 376 US 254 (1964), is inapplicable to opinion or parody.

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Q: What did the court rule in Hustler Magazine v Falwell about collection of damages for words that might cause emotional distress?
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Why did Jerry Falwell take Larry Flynt to court?

Jerry Falwell took Larry Flynt to court because he believed that Flynt's publication, Hustler magazine, had defamed his character by publishing a parody that suggested Falwell had engaged in a drunken incestuous encounter with his mother. Falwell sued Flynt for intentional infliction of emotional distress and invasion of privacy.


What were the constitutional issues in Hustler Magazine v. Falwell 1988?

The main constitutional issue in Hustler Magazine v. Falwell (1988) was whether a public figure could recover damages for emotional distress caused by a parody advertisement in a magazine. The Supreme Court held that the First Amendment protected the magazine's right to satirize public figures, even if the parody was deemed offensive, as long as it could not reasonably be interpreted as stating actual facts.


Who authored the US Supreme Court's majority opinion in Hustler Magazine v Falwell?

Justice William Rehnquist authored the majority opinion in Hustler Magazine v. Falwell, a landmark 1988 case. The Court ruled in favor of Hustler Magazine, holding that the First Amendment protected the publication's parody of the reverend Jerry Falwell.


What were the decisions of the lower courts in the case of Hustler Magazine v Falwell?

Hustler Magazine, Inc. v. Falwell, 485 US 46 (1988)US District CourtJerry 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 CircuitThe 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 CourtThe 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.For more information, see Related Questions, below.


What rules of law applied in Hustler Magazine v Falwell?

In the case of Hustler Magazine v. Falwell, the United States Supreme Court ruled that the First Amendment protected a satirical advertisement published in Hustler magazine, which was considered offensive by Reverend Jerry Falwell. The court held that public figures could not recover for intentional infliction of emotional distress without showing that the publication contained a false statement made with actual malice. This case reaffirmed the importance of protecting freedom of speech and the press, even when the speech is offensive or distasteful.


Did Hustler Magazine v. Falwell overturn New York Times v. Sullivan?

No, Hustler Magazine v. Falwell did not overturn New York Times v. Sullivan. New York Times v. Sullivan established the actual malice standard for defamation of public figures, while Hustler v. Falwell dealt with intentional infliction of emotional distress in a case involving a public figure.


Do public figures who are satirized in comedy skits have a case for slander or libel?

No. Satire is a form of speech protected by the First Amendment. The Supreme Court decision on Hustler Magazine, Inc. v. Falwell, 485 US 46 (1988) was unanimous is saying that the First Amendment prohibits monetary awards to public figures to compensate for emotional distress. This is because satire is exaggerated so that reasonable people will recognize that is has no basis in fact.


How does the decision of Hustler Magazine v. Falwell affect us today?

The Supreme Court ruling in Hustler Magazine v. Falwell in 1988 established that public figures cannot recover damages for emotional distress based on satire and parody. This decision continues to impact free speech protections in the media and limits the ability of public figures to sue for defamation or invasion of privacy in cases where satire or parody is involved.


What is the birth name of Jerry Falwell?

Jerry Falwell's birth name is Jerry Lamon Falwell.


What is the birth name of Jonathan Falwell?

Jonathan Falwell's birth name is Jonathan Pate Falwell.


When was Jonathan Falwell born?

Jonathan Falwell was born in 1966.


Did Larry Flynt's parody of Jerry Falwell damage the preacher's reputation?

Hustler Magazine, Inc. v. Falwell, 485 US 46 (1988)No. Jerry Falwell was a well-known public figure who had already established a reputation for himself prior to Hustlerpublishing the subjectively offensive parody suggesting Falwell lost his virginity to his mother in a drunken encounter in the family outhouse. The "ad" was so preposterous, no reasonable person, friend or foe, would believe it true.Falwell's supporters were understandably outraged, but never wavered in their trust. In fact, Falwell paid his legal expenses with donations from members of the Moral Majority, viewers of Old Time Gospel Hour, and private sources.Some of Falwell's detractors may have been amused (or disgusted), but already had such a low opinion of the preacher the parody would have had no discernible impact. Falwell was a polarizing figure, so there were few people who hadn't already formed an opinion of him by the time the magazine hit newsstands. His reputation was undamaged.For more information, see Related Questions and Related Links, below.