During the 2016 presidential campaign, Donald Trump promised that "I'm going to open up our libel laws so when [news outlets] write purposely negative and horrible and false articles, we can sue them and win lots of money." At that time, it was legal for a public figure to sue a media outlet that was deliberately publishing false and harmful news stories.

Question

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Prior to the 1964 Supreme Court case New York Times Co. v. Sullivan, public figures could sue media outlets for libel even if the statements made were truthful. However, the court ruled that in order for a public figure to successfully sue for libel, they must prove that the statement was not only false, but also made with "actual malice" or reckless disregard for the truth. This protection for media outlets still exists today, and Trump's proposal to "open up our libel laws" would require a repeal of the New York Times Co. v. Sullivan ruling.

During the 2016 Presidential Campaign, Donald Trump Promised That "I'm