St. Amant v. Thompson’s Empirical Analysis
1968
Citation profile
770 federal appellate · 298 district · 1,894 state decisions
How this case has been cited
Cited by 3,837 later decisions (55 by the Supreme Court) — most recently June 2025 · most notably Pickering v. Board of Education of Township High School District 205 Will County Illinois (1968), Gertz v. Robert Welch, Inc. (1974)
770 federal appellate · 298 district · 1,894 state decisions — followed in 46 states
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on New York Times Co. v. Sullivan · Curtis Publishing Co. v. Butts · Garrison v. State of Louisiana · Rosenblatt v. Baer
Cited together with New York Times Co. v. Sullivan · Gertz v. Robert Welch, Inc. · Curtis Publishing Co. v. Butts · Garrison v. State of Louisiana · Bose Corp. v. Consumers Union of United States, Inc.
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 3,837 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[R]eckless conduct is not measured by whether a reasonably prudent man would have published, or would have investigated before publishing. There must be sufficient evidence to permit the conclusion that the defendant in fact entertained serious doubts as to the truth of his publication. Publishing with such doubts shows reckless disregard for truth or falsity and demonstrates actual malice.”
405 later decisions quote this exact passage · from the majority“Criticism of those responsible for government operations must be free, lest criticism of government itself be penalized. It is clear, therefore, that the "public official" designation applies at the very least to those among the hierarchy of government employees who have, or appear to the public to have, substantial responsibility for or control over the conduct of governmental affairs.”
5 later decisions quote this exact passage · from the dissent“St. Amant made his broadcast in June, 1962. He had known Albin since October 1961, when he first met with members of the dissident Teamsters faction. St. Am-ant testified that he had verified other aspects of Albin’s information and that he had affidavits from others. Moreover, Albin swore to his answers, first in writing and later in the presence of newsmen. According to Albin, he was prepared to substantiate his charges. St. Amant knew that Albin was engaged in an internal struggle in the union; Albin seemed to St. Amant to be placing himself in personal danger by publicly airing the details of the dispute.”
2 later decisions quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.