In the only previous case that did present the question of constitutional limitations upon the power to award damages for libel of a public official, the Court was equally divided and the question was not decided.

Most Syndicate cases were decided in the early 1940s, after the decision in Erie, and showcase the broad similarities and subtle variances of the substantive law of defamation among jurisdictions

The only previous case that came near to the novel questions presented by Sullivan was left undecided by an equally divided court

Through the first half of the twentieth century, in judicial opinions, as in both scientific and colloquial discourse, Jewish people were routinely referred to as a "race," often without anti-Semitic connotation.

Schenectady Union Publishing Co. v. Sweeney, the publisher posed precisely the conflict that Thomas asserts had never been thought of prior to Sullivan: “These guarantees [under the First Amendment] bespeak more than a prohibition of 'previous restraints'; a statute imposing subsequent punishment which has the effect of trammelling or embarrassing unduly the …

Such allegations tendered an issue for the jury, but the appellee White did not join issue on them; by his motion to dismiss, he admitted them.

MLE, note, March 14, 1963 (“helped get newsprint to the underground of France”); Henri Bonnet, Ambassador of France, to MLE, November 26, 1951; Legion of Honor certificate, June 1951; all in Ernst Papers.

[CITATION] Dun & Bradstreet, Inc. v. Grove