Libel Law

Nebraska Libel Law derives from court cases decided in this state and in the United States Supreme Court, from statutes found at Nebraska Revised Statutes '' 25-208, 25-839, 25- 840 and 25-840.01, and from the First Amendment to the United States Constitution, Free Speech and Free Press clauses.

Basically, libel law is a series of checks and balances between the concept of free speech and the concept of the right to personal reputation. The technical definition of "libel" is a publication of language, the obvious meaning of which imputes to a person a criminal act, or subjects the person to ridicule or disgrace, public hatred or contempt, and which in essence detracts from the person’s reputation in a substantial way.
To be actionable, a libel must be a false statement, and in most cases it must be a statement of fact, not a statement of opinion. Truth is a "defense," but actually the burden of proving falsity is on the plaintiff or complaining party, rather than on the defendant to prove the truth. That applies both in public figure and private figure plaintiff cases.

In cases where a person is a public official and acting in an official capacity, or a public figure who has voluntarily put himself in the spotlight, then almost all of the applicable law derives from United States Supreme Court decisions and the First Amendment to the Constitution. In those cases, particularly New York Times v. Sullivan decided in 1964, and the many cases which have explained that case, such a complaining party is required to prove that the defendant not only published a false fact, but that the defendant actually knew of the falsity or at least had very strong doubts of the truth of what was being published. That is the concept of "actual malice."

In private figure cases, the burden is still on the plaintiff to show not only that a false fact was published of him which would damage his reputation, but also that it was a result of some degree of fault although not fault so extreme as "actual malice." In most states, it is necessary for the plaintiff still to prove that negligence on the part of the publisher resulted in that publication of the falsehood.

The Nebraska Supreme Court has not yet defined exactly what standard will apply here but one should assume that if it can be proved that your reporters, editors and/or publisher breached the normal professional standard of care in gathering, editing and publishing a news or informational item, then if it is false, a private figure who is damaged thereby might succeed in a libel case. In other words, assume that mere negligence may well become the standard of fault required to be proved in Nebraska. Nevertheless, it should be understood that a totally innocent error where due care was used and yet the error still occurred, is not actionable in libel. Some fault has to be proved.

Libel or slander
In an action for a libel or slander it shall be sufficient to state generally that the defamatory matter was published or spoken of the plaintiff, and if the allegation be denied, the plaintiff must prove on the trial the facts showing that the defamatory matter was published or spoken of him.

The truth in itself and alone shall be a complete defense unless it shall be proved by the plaintiff that the publication was made with actual malice. Actual malice shall not be inferred or presumed from publication.

In an action for damages, the plaintiff shall recover no more than special damages, unless correction was requested and was not published. The term special damages, as used in this section, shall include only such damages as plaintiff alleges and proves were suffered in respect to his or her property, business, trade, profession or occupation as the direct and proximate result of the defendant’s publication.

Defenses After Litigation is Filed

The Story Was Substantially True.

The Publisher Used Due Care to Avoid the Error but it Inadvertently Occurred Anyway.

The Story was Essentially Opinion, not Assertions of Fact.

Absolute or Qualified Privilege.
There is an absolute privilege in very few cases for newspapers to print libels. Senators have an absolute privilege when they are on the floor of the Unicameral, and persons reporting alleged wrongs to professional supervisory bodies such as the bar association, etc., have an absolute privilege. Lawyers and witnesses have a privilege also during the course of legal proceedings to make statements that might otherwise be libelous.
Frequently, however, newspapers are given a "qualified privilege"; that is, a privilege to print something otherwise libelous in the absence of having actual knowledge of falsity, or having an intention to injury someone. A qualified privilege attaches to the printing of information taken accurately from any public record, at least where one does not know it to be false.

Retraction.
This defense is a partial defense, limiting damages to special or out-of- pocket losses except where malice is proved against the publisher.

No Actual Damage to Reputation Proved.
Plaintiffs frequently, indeed almost uniformly, exaggerate their loss of reputation for strategic, litigation-aimed reasons.

If the Plaintiff is a Public Figure or Public Official, the Lack of Knowledge of Falsity, or Lack of "Malice" in the Constitutional Sense, is a Defense.
(Burden of proving such malice is always on the plaintiff.)

Reportorial Privilege. (Correct quotation from a reliable source).
In this regard, attribution is extremely important both as a matter of preventive action and in some cases as a defense to a libel suit after filed. In other words, it may be defensible to quote a highly reputable source of information, even if later on that information turns out to be false and libelous. This defense is not commonly honored but has been used successfully on a few occasions. It is akin to a "privilege" to trust such a source. In some recent cases, the reliance on an established news wire service is deemed to be non-negligent, if an error is present in the wire services copy.

Prevention of Libel.

Sources.
If you have only a single source and that source insists on confidentiality, then you are in a rigorously dangerous situation if you print reputation-injuring material. Because if you are sued for libel, you will face the moral and possibly legal choice of either disclosing your source contrary to your promise, or losing the libel case because you are unable to satisfy the judge and jury that you used due care to find the truth. If at all possible, obviously it is best to find a source who will back you up, and better yet find two sources at least one of which is unimpeachable, for highly damaging material which must be printed. The quality of sources is also important, which means that their reputation, background, previous dependability, likelihood to have true information, and similar factors ought to be taken into account in evaluating material which is reputation-injury.


Care with Headlines, Syntax and Captions.
It is quite possible to have a perfectly good story turned in and then have it made libelous accidentally by a careless headline, by an editing error whereby the words are turned around or even typographically changed, or where the caption of a photograph, for example, is switched or inaccurately placed or worded. There should be extreme care used especially with headlines, because even though you are entitled to the context of the whole story, a highly libelous headline sometimes will be so damaging that even the context will not cure the problem.

Letters to the Editor.
The publisher is liable for libel in letters to the editor, and therefore care especially must be taken with letters to the editor on emotional subjects, customer complaint or "action line" stories and the like. If highly damaging statements of fact are in a letter to the editor about some person or company, it is wise to treat it with care. Either find an independent means to verify the truth of the statement, force the writer of the letter to the editor to supply sufficient proof, or edit out the libelous material, normally after consultation with the writer of the letter. Many newspapers use letters to the editor which were signed, but the signature was withheld. The Nebraska Shield Law permits you to withhold that name, and that law has been tested in that context. But withholding the name of the author simply means that the newspaper itself will take all the "heat" in the event there is a libel or breach of privacy case. Letters to the editors have furnished the material for numerous libel cases all around the country and while they are an extremely important and necessary part of a newspaper, in most people’s view, nevertheless they require special attention and "libel proofing."

Jokes and Cartoons.
Sometimes the law of libel has little sense of humor. A highly satirical joke or cartoon has occasionally been made the subject of a successful libel lawsuit. There is a great deal of defense allowed to newspapers and cartoonists on the basis that they are writing only satirically and expressing an opinion, but nevertheless it is not impossible to make a libel case out of a cartoon or other humorous material, if in fact it does contain a false statement of fact injuring a reputation. A picture could imply a false statement of fact even though it be a mere cartoon. While there is great protection for political criticism and public issue humorous comment, nevertheless this is an area where the libel-conscious editor needs to do some good preventive work. Nationally distributed cartoons are generally "libel-proofed" nationally, and are relatively safe.

Balancing News Stories.
It is important where a reputation-damaging story is about to be run to try to obtain a comment from the subject. If the answer is no comment, print that. If the subject denies the material, print that. If the subject threatens a lawsuit, make very sure your sources are verifiable and that the truth is with you. If you can’t be confident of that, either get legal help or work some more on the story before it runs. By balancing news stories, one should not necessarily attempt a balance in the terms of space given to each side. It is simply a matter of trying to get the other side of the story if there is one and giving it fair play where available.

Editing.
On stories which appear to injure the reputation of a person or business enterprise, one extra editing even at the page proof stage may knock out a dangerous typographical error or something that simply missed being caught on the first rewrite. That extra editing also would be evidence of due care and would help avoid a claim of negligence.

Proper Use of Retraction Statute.
Under Nebraska law, even if a publisher prints a libel, the publisher will be subject only to actual or "special" damages, if a retraction is timely printed. Do not, however, retract and admit fault if in fact you are not satisfied that there was genuine error. If the complaining party tries to prove "actual malice" against you, the retraction statute is nullified, and your having admitted fault may work against you in those cases. Nevertheless, in any case where an actual error is pointed out, whether it be for libel, or simply for newspaper integrity purposes, the retraction statute is extremely useful both in defusing the situation and in limiting damages in many cases. It is a highly valuable tool in libel prevention.

Settlement by Apology.
Closely related to the retraction statute is a settlement done by personal apology where an error has been made. It is important in such cases to try to bring the matter to a close at the time the apology is rendered; that is, try to get an agreement by letter or by witnessed conversation at the very least, that the matter is deemed to be at a close. It is not wise, in the author’s opinion, to offer "nuisance settlements" on any libel cases. Those encourage additional claims and also encourage lawyers to start filing more cases. If cash settlement is ever considered, it should only be after extremely close scrutiny of the liability and damages issues with the assistance of your insurer, if any, and counsel.

Closing Comment on Libel

The danger of libel is a real one, even in Nebraska where we do not allow "punitive" damages to be collected by anyone, but it is at least as dangerous to allow concern over libel to shut off necessary news, information and opinion.
The Nebraska Supreme Court has been relatively favorable to libel defendants and there are very few successful libel cases against the records of Nebraska newspapers. Attention to detail, special care for stories which obviously injure reputation, and a general sensitivity to the potential defenses and to writing courteous, prompt retractions will defuse the vast majority of all libel problems in this state.
Where a particular story is troublesome but it is nevertheless highly important that it be printed, there is almost always a way. The extra work to come up with an additional source, careful use of language to create a "libel-proof" way to say the truth, and an honest attempt to balance out the story by getting the adversely affected side’s viewpoint will permit the newspaper to do its job without libel jeopardy.

Time Limits.
The following actions can only be brought within the periods stated in this section:
Within one year, an action for libel, slander, assault and battery, false imprisonment, or malicious prosecution or an action upon a statute for a penalty or forfeiture, but if the statute giving such action prescribes a different limitation, the action may be brought within the period so limited; and within two years, an action for malpractice which is not otherwise specifically limited by statute.


Within twenty days after knowledge of the publication, plaintiff shall have given each defendant a notice by registered mail specifying the statements claimed to be libelous or to have invaded privacy as provided by section 20-204 and specifically requesting correction.
Publication of a correction shall be made within three weeks after receipt of the request. It shall be made in substantially as conspicuous a manner as the original publication about which complaint was made. A correction, published prior to receipt of a request therefor, shall have the same force and effect as if published after such request.

This section shall not apply if it is alleged and proved that the publication was prompted by actual malice, and actual malice shall not be inferred or presumed from the publication.