Palin v. New York Times Co. Case Brief Summary | Law Case Explained

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Palin v. New York Times Co.
United States Court of Appeals for the Second Circuit
940 F.3d 804 (2019)

In Palin versus New York Times, we'll see whether a district court erred when it dismissed a complaint after relying on facts outside of the pleadings.

In twenty eleven, Jared Loughner opened fire at a political rally for congresswoman Gabrielle Giffords.

Prior to the shooting, Sarah Palin's political action committee known as Sarah PAC published a map that superimposed crosshair targets over Democratic congressional districts, including Giffords district.

Investigators found that Loughner's motive for shooting Giffords wasn't related to the map.

After another political shooting in twenty seventeen, the New York Times published an editorial written by James Bennett that discussed the recent shooting as well as Loughner's shooting. The article suggested that there was a connection between the Sarah PAC map and Loughner's shooting. The next day, the Times issued a correction stating that there wasn't an established link between Loughner's shooting and the map.

Palin sued the Times for defamation.

The Times moved to dismiss Palin's complaint for failure to state a claim. The district court judge held an evidentiary hearing to assess whether Palin sufficiently pleaded the required actual malice element.

At the hearing, Bennett explained that he only wanted to make a rhetorical point about political anger when he referenced the Sarah Pak map and Loughner's shooting.

Bennett claims that he didn't know that there wasn't a connection between the map and the shooting.

Following the hearing, the court granted the time's motion to dismiss and dismissed Palin's complaint with prejudice.

Palin filed a motion for reconsideration regarding the court's decision to dismiss her complaint with prejudice.

Palin included a proposed amended complaint with her motion that claimed that Bennett acted with actual malice because he had a predetermined argument for his editorial, which caused him to publish statements that he knew were false. Palin's amended complaint argued that Bennett's background as an editor was sufficient to show he acted with actual malice because he should have known that previous articles found that there wasn't a connection between the map and the shooting. The district court denied Palin's motion for reconsideration and denied Palin leave to amend her complaint.

Palin appealed.

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