New York Times Co. v. Sullivan · ¶61

“We think it common knowledge that the average person knows that municipal agents, such as police and firemen, and others, are under the control and direction of the city governing body, and more particularly under the direction and control of a single commissioner. In measuring the performance or deficiencies of such groups, praise or criticism is usually attached to the official in complete control of the body.” 273 Ala., at 674-675, 144 So. 2d, at 39.

U. S. Reports, bound volume
U. S. Reports, volume 376, at 254 (Library of Congress) · transcription: Caselaw Access Project
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