## Facts

- A local weekly newspaper in Greenbelt, Maryland reported on contentious city council meetings concerning zoning variances sought by Charles S. Bresler, a prominent real estate developer and state legislator.
- During the same period, the city was negotiating to acquire another Bresler-owned tract as a site for a new high school.
- At the public meetings, some citizens characterized Bresler’s negotiating position as “blackmail”; the term appeared in the newspaper’s coverage, sometimes in quotation marks and once as a subheading.
- The articles also included contrary views, including a council member’s description of the situation as ordinary “two-way” negotiations.
- It was undisputed that the newspaper accurately reported what was said at the meetings.
- Bresler, a conceded public figure, sued the newspaper for libel, claiming the publications accused him of the crime of blackmail.
- A Maryland jury awarded Bresler compensatory and punitive damages; the Maryland Court of Appeals affirmed.

## Issues

1. Whether a newspaper may be held liable for libel for accurately reporting that speakers at a public meeting described a public figure’s negotiating position as “blackmail.”
2. Whether jury instructions defining “malice” as spite, hostility, or intent to harm (rather than constitutional “actual malice”) violate the First and Fourteenth Amendments in a public-figure defamation case.

## Decision

- The Supreme Court reversed and remanded.
- The Court held that imposing liability based on the reported “hostile remarks” made in a public debate impermissibly burdened freedom of speech and the press.
- The Court concluded that, in context, “blackmail” was rhetorical hyperbole and would not be understood by a reasonable reader as a literal accusation that Bresler committed the crime of blackmail.
- The Court further held that the trial court’s malice instruction departed from the constitutionally required “actual malice” standard.

## Legal Principles

- A public official or public figure may recover for defamation only upon proof of “actual malice,” meaning knowledge of falsity or reckless disregard for truth.
- Courts must assess allegedly defamatory words in full context; language that is plainly figurative or rhetorical hyperbole and not reasonably understood as stating actual facts is not actionable.
- Accurate reporting of heated criticism voiced during debate on public issues is constitutionally protected; liability cannot rest on the harshness or hostility of the reported remarks.

## Conclusion

Because the newspaper accurately reported statements made at public meetings on matters of public concern and the term “blackmail” was used as a figurative epithet rather than a literal charge of criminal conduct, the First Amendment barred the libel judgment, and the jury instructions improperly allowed liability without the constitutionally required showing of actual malice.


Greenbelt Coop. Publ’g Ass’n v. Bresler, 398 U.S. 6 (1970)