In New York Times Co. v. Sullivan four years ago, the Supreme Court laid down tough constitutional limitations on libel recoveries by public officials. "A defamatory falsehood relating to his official conduct," ruled the court, must be "made with 'actual malice'—that is, with knowledge that it was false or with reckless disregard of whether it was false or not." So much for public officials. But what of persons very much in the public eye, though not public officials? They too play an important part in shaping the course and creeds of the country. Should not the press be permitted to write...
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