Nonprofits for the first time received endorsement to use advertisements to discuss matters of public relations following what 1964 US Supreme Court case?

Question

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New York Times v. Sullivan (1964) is a landmark Supreme Court case that established the "actual malice" standard, which has to be met for press reports about public officials to be considered defamation or libel. This case significantly protected the freedom of the press, allowing for more open discussion and critique of public figures and matters of public concern, including through advertisements.

Nonprofits for the First Time Received Endorsement to Use Advertisements