Harte-Hanks Communications Inc. v. Connaughton, 491 U.S. 657 (1989), was a case in which the Supreme Court of the United States supplied an additional journalistic behavior that constitutes actual malice as first discussed in New York Times Co. v. Sullivan (1964).

[2] In November 1983, Daniel Connaughton unsuccessfully ran for the position of Municipal Judge of Hamilton, Ohio, losing to incumbent James Dolan.

On November 1, 1983, while a grand jury investigation of the charges was taking place, the JournalNews ran a front page article quoting Alice Thompson, a witness in the trial.

Harte-Hanks pushed for summary judgment, arguing that even if Thompson's statements were false, the article was protected under the neutral reportage privilege.

Justice Stevens began his opinion by referencing New York Times Co. v. Sullivan (1964)[1] and Curtis Publishing Co. v. Butts (1967),[4] which state that public figures, such as Connaughton, must definitively prove actual malice to be awarded damages in libel suits.

He then referenced the case Hustler Magazine v. Falwell (1988), which had occurred the year before, and had ruled that public figures "may not recover for the tort of intentional infliction of emotional distress .

Justice Stevens also wrote that "if the Journal News had serious doubts concerning the truth of Thompson's remarks, but was committed to running the story, there was good reason not to interview Stephens."

Justice Stevens then explains that while public figures can legally endure more defamation than private persons, they are not completely unprotected by the courts, provided they can prove the defendants acted with actual malice.