New York Times v. Sullivan (1964)
• Martin Luther King supporters take out ad in New York Times
• Criticize Montgomery Police Commissioner Sullivan
• “They have arrested [King] seven times…”
• Actually, King was arrested 4 times, “detained” 3 times
• Initially found liable for defamation
• SCOTUS invents the “Public Official Plaintiff” and “Actual Malice” standard

SCOTUS: Actual Malice - knowledge that the defamatory statement was false or made with reckless disregard of whether it was false or not.
N.Y. Times Co. v. Sullivan, 376 U.S. 254, 256, 84 S. Ct. 710, 713 (1964)