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 result from actual malice, which means the defendant made the statement with knowledge that it was false or with reckless disregard of whether it was false or not. This high standard of proof helps ensure that the freedom of the press is protected while giving private citizens a way to seek damages for defamatory statements made about them.

In the 1964 Case of New York Times V