In the 1967 case Associated Press v. Walker, the U.S. Supreme Court ruled in favor of news agency The Associated Press (AP). The dispute arose when AP published an article about Edwin A. Walker's conduct during a University of Mississippi riot against racial integration, which he claimed was defamatory and false. However, the court held that even if some inaccuracies were present in the reportage on public figures or events of public importance, they did not necessarily constitute "actual malice". This term refers to publishing information with knowledge of its falsity or with reckless disregard for its truthfulness - a standard established by New York Times Co v Sullivan (1964) for defamation cases involving public officials. Therefore, unless it could be proven that AP had acted with actual malice when reporting on Walker's actions at the university riot – which was not demonstrated – no liability would attach to any errors made.

In the dissenting opinion for Associated Press v. Walker, Justice Hugo Black argued that public figures should not be held to a different standard than private individuals when it comes to defamation law. He disagreed with the majority's decision which required public figures to prove "actual malice" in order to win a defamation lawsuit, stating that this created an unfair burden on those who have chosen or been thrust into the public eye. Furthermore, he expressed concern about how this ruling could potentially limit freedom of speech by discouraging criticism of public officials and other prominent individuals out of fear of litigation. In his view, all citizens should enjoy equal protection under libel laws regardless of their status as private or public figures.