Cohen v. Cowles Media Co. (Minn.)

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Cohen v. Cowles Media Co. (Minn.)
Court Supreme Court of Minnesota
Citation 457 N.W.2d 199 (1990)
Date decided 1990
Appealed from Minnesota State Court of Appeals
Related Cohen v. Cowles Media Co.

Relevant Facts

The plaintiff, Dan Cohen, was promised by the defendants Northwest Publications, Inc. and the Pioneer Press that his name would not be disclosed in exchange for some documents which leaked information about a politician running in an upcoming election. They decided to print his name as the source of the information, against the reporter’s judgment.


Procedural History

The jury awarded Cohen $200,000 compensatory damages, and $250,000 punitive damages. The appeals court set aside the punitive damages, because misrepresentation had not been proved.


Issues

Whether the first amendment prohibits a plaintiff from recovering damages, under state promissory estoppel law, for a newspaper’s breach of a promise of confidentiality given to the plaintiff in exchange for information.


Holding/Decision

Judgment reversed.

RulesIn deciding whether it would be unjust not to enforce the promise, the court must necessarily weigh the same considerations that are weighed for whether the First Amendment has been violated.ConclusionIt seems that the law best leaves the parties to trust in each other, so that freedom of press is more important than enforcing this contract.