In which case did the Supreme Court privilege free and robust political speech over the pains that politicians, even presidents, might feel when criticized in the press?

Question

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New York Times Co. v. Sullivan (1964) established the principle that public officials must prove actual malice to bring a defamation suit against a news outlet. This meant that politicians, even presidents, could be criticized in the press without fear of legal reprisal, as long as the outlet did not knowingly or recklessly publish a false statement about them. This decision privileged free and robust political speech over the potential harm that politicians might feel from such criticism.

In Which Case Did the Supreme Court Privilege Free and Robust