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

le which alleged that Butts, the athletic director at University of Georgia, and Paul "Bear" Bryant, the head football coach at the University of Alabama, had conspired to fix a football game between their teams. The publishers said that the story came from a citizen who had claimed that he had tapped into a telephone conversation between the two parties. The lower court found the publishers liable for defamation and the Supreme Court upheld this ruling. The Court said that while the defendants did not know the story was false, its decision to publish the story on the basis of this one citizen's strange tale violated basic journalistic standards. Thus, the Court held that the lesser standard of gross negligence was more appropriate than the actual malice standard. Thus, the plaintiff had to prove that the defendant publishers engaged in "highly unreasonable conduct constituting an extreme departure from the standards of investigation and reporting ordinarily adhered to by responsible publishers." The Court, however, failed to define the term "public figure," noting only that the plaintiff in this case was the subject of a substantial amount of public interest.

In cases involving school administrators, courts have usually pointed to the public nature of an administrator's duties. A college administrator is "often called upon to make public speeches, formulate and implement policy decisions, introduce guest speakers at the college, and to interact with the citizenry of the surrounding community." With regard to coaches, courts have also looked at the high profile nature of sports in finding public figure status. One court said that the plaintiff had placed himself in the "forefront of an already existing public controversy regarding alleged recruiting violations at the university." The court went on to say that the coaching position in question "may be so prominent that any occupant unavoidably ente