Which Supreme Court case established the 'actual malice' standard for libel of public figures?

New York Times v. Sullivan established the “actual malice” standard for libel suits involving public officials and, later, public figures.

Decided unanimously in 1964, the case arose after The New York Times published an advertisement criticizing officials in Montgomery, Alabama, during the civil-rights movement. L. B. Sullivan, a city public-safety commissioner, sued even though the advertisement did not name him directly. Alabama courts initially awarded him damages.

The U.S. Supreme Court reversed that judgment, holding that public officials must prove that a defamatory statement was published either knowing it was false or with reckless disregard for whether it was false. “Actual malice” therefore does not mean personal hatred or ill will; it is a demanding constitutional standard about the publisher’s knowledge or conduct.

The ruling protected robust criticism of government and public officials under the First Amendment. In Curtis Publishing Co. v. Butts (1967), the Court extended the standard to public figures. Texas v. Johnson concerns flag burning, Hustler Magazine v. Falwell involves intentional emotional distress, and Gertz v. Robert Welch addresses private figures.