In the only two false light cases the U.S.Supreme Court has decided,it said all plaintiffs must prove actual malice.Some lower courts also require all false light plaintiffs to prove actual malice.Others require only public officials and public figures to prove actual malice.

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The statement is correct, as the U.S. Supreme Court has ruled that all plaintiffs in false light cases must prove actual malice. Some lower courts do also require actual malice for public officials and public figures, while others may apply a lower standard for private individuals.

In the Only Two False Light Cases the U