Harte-Hanks Communications V. Connaughton Case Study

Harte- Hanks Communications v. Connaughton, which took place in 1989, focused around libel laws as well redefining the actual malice standard. Six years prior to the case, Daniel Connaughton ran for Municipal Judge of Hamilton, Ohio, losing to the incumbent James Dolan. Connaughton was ultimately unsuccessful, losing to Dolan, who was supported by JournalNews, a local Ohio paper. It later was revealed that prior to the election, a member of Dolan’s staff resigned his position and was charged with perjury, by a jury. During the grand jury investigation, at the end of 1983, the JournalNews ran a piece quoting a witness in the trial, Alice Thompson. Thompson allegedly reported that Connaughton used “dirty tricks” while running for the position. It was also speculated that Connaughton offered Thompson and her sister compensation, in

He believed the article was incorrect and resulted in personal, professional, and political injuries to his reputation. He argued that the article was published “on the grounds of actual malice.” Actual malice is defined as “a condition required to establish libel against public officials or public figures and is defined as ‘knowledge that the information was false’ or that it was published ‘with reckless disregard of whether it was false or not,’” (Merriam-Webster). On the defendant's side, Harte-Hanks Communication, believed that Connaughton’s statements were incorrect. They argued that the article was protected under the neutral reporting privilege, which “is designed to protect the interests of the press in reporting on matters of public interest, which can often only be done by reporting accusations made by one public figure about another” (Digital Media Law). The District Court would eventually deny their motion on the grounds that it could not be proven that the article was written with