By the time the case reached the U.S. Supreme Court in 1991, the key issue was whether [Janet] Malcolm’s changes in the wording of Masson’s quotations rendered her story knowingly false — the standard that Masson, a public figure, would need to prove to win his libel suit.
In extending latitude to writers, the court found that “deliberate alteration of the words ... does not equate with knowledge of falsity ... unless the alteration results in a material change in the meaning conveyed by the statement.”
While the case was important because it helped to further clarify libel law, its significance was further felt in unveiling the tension between traditional, fact-bound reporting and the kind of literary journalism that had been popularized in magazines like the New Yorker.
Although Masson v. New Yorker was a defamation case, it also was a trial of literary versus traditional journalism. As Kathy Roberts Forde suggests in her compelling book, the struggle between the two forms has a history that long pre-dates the Supreme Court case.
Objectivity as a tenet of journalism was a natural extension of the growth of “pure science” — relying “on observation and measurement to explain the world” — that solidified in the late 1800s at universities across the country and soon spilled over into the social sciences. As Forde points out, “[b]y the 1920s, journalism had turned toward the social sciences.”
Robert D. Richards on "Literary Journalism on Trial", by Kathy Roberts Forde.