Warren E. Spahn v. Julian Messner, Inc.

Summary

The New York Court of Appeals affirmed the injunction and $10,000 damages against the author and publisher of a fictionalized biography of baseball pitcher Warren Spahn, holding that a public figure must prove material falsification and actual malice to recover under sections 50 and 51 of the Civil Rights Law. The Court applied the standards of New York Times Co. v. Sullivan and Time, Inc. v. Hill, finding the defendants’ work contained invented dialogue and false statements published with reckless disregard for the truth. The dissent argued that the statute should not apply to fictionalized works about public figures and would reverse the decision.