In the 1964 case of New York Times v.Sullivan, the Supreme Court held that to be deemed libelous a story had to

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The Supreme Court held that for a story to be deemed libelous, it had to be untrue and published with actual malice, meaning with knowledge that it was false or with reckless disregard for whether it was false or not. This standard was set to protect freedom of speech under the First Amendment, particularly for statements about public officials.

In the 1964 Case of New York Times V