What Was the Significance of the Libel Cases of Goldwater

What was the significance of the libel cases of Goldwater v. Ginzburg, Harte- Hanks Communications v. Connaughton, and Turner v. KTRK?

A) they established that because of the "actual malice" rule, political candidates and other public figures have zero chance of winning libel suits
B) they established that no one is "libel proof," and that it is possible for political candidates and other public figures to meet the "actual malice" standard and win libel suits if their cases are strong enough
C) they led to rulings that being charged with a serious crime is enough to make a person a public figure, even if he or she was not a public figure beforehand
D) they led to rulings that just being charged with a serious crime does not make a person a "public figure" if he or she was not a public figure beforehand