Walter Sweeney, Respondent v. Prisoners’ Legal Services of New York, Inc., Appellants

Summary

The New York Court of Appeals reversed the Appellate Division’s finding of actual malice and dismissed the defamation suit, holding that the plaintiff, a correction officer, failed to prove by clear and convincing evidence that the defendants published a false statement with knowledge of its falsity or reckless disregard. The court affirmed that a qualified privilege applies and that a defendant’s mere failure to investigate does not satisfy the actual malice standard.