The document discusses the evolution of libel law in the United States, beginning with the 1964 Supreme Court case New York Times Co. v. Sullivan. This ruling established the "actual malice" standard, requiring that public officials prove a statement was made with knowledge of its falsity or reckless disregard for the truth in order to win a libel suit. The ruling marked a shift toward protecting press freedom and criticism of public figures under the First Amendment. Subsequent cases extended this standard and defined what constitutes reckless disregard, changing the landscape of libel significantly in favor of media defendants.