The Public Figure Doctrine
 The Supreme Court agreed, holding that when a defamatory statement concerns a public official, that official must show actual malice on the part of the defendant in making the statement. Actual malice in this context means that the defendant must have had actual knowledge that the statement is false or act with reckless disregard of whether the statement is true or false.

The Court reasoned that without such restrictions on the law of defamation, defendants would censor themselves. This could mean that individuals would avoid criticizing public officials out of the fear of liability, even though the public had an important interest in those figures. The Court recognized that occasional false statements are inevitable in free debate and must be tolerated in order to prevent a chilling effect on the free exchange of ideas. Thus, requiring a showing of actual malice served the First Amendment's goal of promoting uninhibited, robust, and open debate on the activities of those persons holding the public's trust.

The Court expanded this First Amendment protection to situations involving public figures, as well as officials, in 1967. In Curtis Publishing Co. v. Butts, the publishers of the Saturday Evening Post were sued for defamation arising out of an artic

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