Hearst v. Halligan was a United States Supreme Court case that addressed the issue of whether a state court could enjoin a newspaper from publishing a libelous article. The case arose when the plaintiff, Hearst, published an article in a newspaper that accused Halligan of being a thief and a liar. Halligan sued Hearst for libel and obtained an injunction from the state court prohibiting Hearst from publishing the article. Hearst appealed the injunction to the Supreme Court, arguing that the state court had no authority to enjoin the publication of the article. The Supreme Court held that the state court did not have the authority to enjoin the publication of the article. The Court reasoned that the First Amendment of the United States Constitution protects the freedom of the press and that the state court's injunction was an unconstitutional prior restraint on the press. The Court further held that the state court's injunction was an unconstitutional infringement on the freedom of the press and that the state court had no authority to enjoin the publication of the article. In conclusion, the Supreme Court held that the state court did not have the authority to enjoin the publication of the article and that the injunction was an unconstitutional prior restraint on the press. The Court's decision established an important precedent that the freedom of the press is protected by the First Amendment and that state courts cannot enjoin the publication of articles.

Justice Harlan wrote the dissenting opinion in Hearst v. Halligan, arguing that the majority's decision was a violation of due process and an infringement on freedom of speech. He argued that since libel is not a crime under New York law, it should not be treated as such by the court. Furthermore, he asserted that if criminal sanctions were to be imposed for libelous statements then they must meet certain criteria: 1) The statement must have been made with malicious intent; 2) It must have caused actual harm or injury; 3) There must be proof beyond reasonable doubt before any conviction can take place. Justice Harlan concluded his dissent by stating that while some forms of expression may deserve punishment, this case did not meet those standards and thus could not justify criminal proceedings against Hearst.