In 1930, a New York State Court Ruled That "Everyone

In 1930, a New York state court ruled that "everyone has the right to (speak about) matters of public interest and concern, provided they do so . . . with an honest purpose . . . such (words) or criticisms are not libelous, no matter how severe in their terms." That ruling established what legal principle that is still applied in libel cases today?

A) the time, place, and manner defense
B) the Blackstonian Doctrine defense
C) the distinction between "hate speech" and "fighting words"
D) the "opinion" or "fair comment" defense
E) the "privilege" defense