## Facts

- A journalist-author wrote a best-selling nonfiction book about the Great Migration, using individual life stories to explain broader social and political changes.
- One central subject’s life story included her marriage to Luther Haynes and later events involving him and his subsequent wife, Dorothy Haynes.
- The book portrayed Luther Haynes negatively, including allegations of heavy drinking, adultery, unstable employment, and irresponsible conduct as a husband and worker.
- Luther and Dorothy Haynes sued the author and publisher under Illinois law for libel and invasion of privacy (public disclosure of private facts).
- The district court granted summary judgment for the defendants on all claims, and the plaintiffs appealed.

## Issues

1. Whether the challenged statements about Luther Haynes were materially false and defamatory, considering substantial truth and any incremental reputational harm.
2. Whether publication of embarrassing details about the plaintiffs constituted public disclosure of private facts under Illinois law, including whether the facts were highly offensive and not of legitimate public concern.
3. How First Amendment protections for publication of newsworthy information constrain defamation and privacy tort liability for nonfiction works.

## Decision

- The court affirmed summary judgment for the author and publisher on both the libel and privacy claims.
- The libel claim failed because any inaccuracies were not material; the overall “gist” was substantially true and did not meaningfully worsen Luther Haynes’s reputation.
- The public-disclosure claim failed because the information was newsworthy and connected to a matter of legitimate public concern in a work of social and political history.
- The First Amendment significantly limits liability for publishing truthful (or substantially true) facts that contribute to public understanding of matters of public importance, even when the subject is a private person.

## Legal Principles

- Defamation liability requires a materially false statement; minor inaccuracies that do not change the “gist” of the publication are not actionable under the substantial-truth doctrine.
- Reputational injury requires more than technical falsity; courts may consider whether the publication causes meaningful incremental harm beyond the plaintiff’s existing reputation.
- Public disclosure of private facts requires proof that (1) the disclosed facts would be highly offensive to a reasonable person and (2) the public lacks a legitimate interest in the facts.
- When disclosed facts are newsworthy and tied to matters of legitimate public concern, the First Amendment restricts privacy-tort recovery, including for private individuals who did not seek public attention.
- A person’s connection to a newsworthy narrative can result in an involuntary loss of privacy that does not, by itself, create a right to suppress truthful publication.

## Conclusion

The Seventh Circuit held that the challenged portrayal was not actionable libel because any errors were immaterial and the account was substantially true, and it held that the privacy claim was barred because the disclosures were newsworthy and constitutionally protected in a nonfiction work addressing matters of public concern.


Haynes v. Alfred A. Knopf, Inc., 8 F.3d 1222 (7th Cir. 1993)