The Supreme Court has held that a public figure who sues for intentional infliction of emotional distress must prove actual malice on the part of a media defendant,just as he/she would in a libel case.The Supreme Court announced this principle in:

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The Supreme Court announced this principle in Hustler Magazine v. Falwell. In that case, the Court held that public figures must prove actual malice to prevail in a claim for intentional infliction of emotional distress against a media defendant.

The Supreme Court Has Held That a Public Figure Who