why was the award for emotional distress in hustler magazine v falwell unanimously reversed
Hustler Magazine, Inc. v. Falwell, 485 US 46 (1988) The lower courts incorrectly allowed a civil jury to award Jerry Falwell a total of $200,000 in compensatory and punitive damages for intentional infliction of emotional distress, under the actual malice standard established in New York Times v. Sullivan, 376 US 254 (1964).